2006 (1) TMI 603

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....ces were sent under Section 143(2) of the Act. During the course of the assessment, it is noticed by the assessing officer that during the previous year relevant to the assessment year under consideration in the balance sheet filed with return of income shows an increased amount Rs. 10,00,000/- in respect of 24 persons. The assessing officer called upon the assessee to prove that the aforesaid amount belongs to the above mentioned 24 persons. Since the assessee failed to produce the applicants who sought for allotment of shares, doubting the transaction has treated the aforesaid amount as income of the assessee and accordingly, an order of assessment was passed. 2. Aggrieved by the same, the assessee filed an appeal before the Commission....

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.... assessee has collected money for allotment of shares to an extent of Rs. 10,00,000/- in respect of 24 persons and the assessing officer has doubted the transaction as not a genuine transaction. Accordingly, the assessee was called upon to produce the documents to show that such applications were really filed by the applicants. The assessee has produced the document to show that such appications were received by it for allotment of shares and thereafter an enquiry has been conducted. Some of the applicants have confirmed the applications made by them and some of the applicants did not appear and even the notice sent to them have been returned with a share "No such person". The assessing officer only relying on the ground that the assessee h....