2018 (1) TMI 588

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....der section 139(1) of the I.T. Act on 30th October, 2007 declaring NIL income. A detailed information regarding accommodation entries provided by M/s. Basant Marketing (P) Ltd., and M/s. Empire Commercial Co. (P) Ltd., to various beneficiary companies was received from the Office of the Commissioner of Income Tax (Central), Kolkata with regard to CBI Investigation in the case of Shri Arun Dalmia, Shri Harsh Dalmia and their dummy companies. The relevant extract of the information received from CIT (Central), Kolkata is reproduced in the assessment order. The list was appended to the said letter contains the names of the beneficiaries of the accommodation entries received from the dummy companies. In the said list name of the assessee was me....

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....06-07. Therefore, submission of the assessee was accepted. The A.O. however, proceeded to examine the issue of disallowance under section 14A of the I.T. Act and made the addition of Rs. 40,51,979. 3. The assessee challenged the reopening of the assessment as well as addition made under section 14A before the Ld. CIT(A). it was submitted that the assessment has been reopened on the reason that assessee obtained accommodation entries in assessment year under appeal amounting to Rs. 2,07,85,000, however, no such transaction has been conducted in assessment year under appeal. Therefore, reasons are recorded on incorrect facts. Therefore, there were no justification to reopen the assessment. The assessee relied upon various decisions incl....