2003 (3) TMI 77

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....as delivered by S.H. KAPADIA J.-A search and seizure operation, under section 132, was conducted on August 3, 2000, in the case of Shri Manoj Agarwal and his associate concerns. The papers found during the course of search and the investigation done during the assessment proceedings showed that Shri Manoj Agarwal used to give accommodation book entries of various kinds to the beneficiaries of t....

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....e 19, 2002 he made a statement before the Income-tax Department, which reads as under: "I have never done any genuine share transaction of profit, either in my name or in my family member's name or in the name of concerns like Friends Portfolio Private Limited. The accommodation entries of profits were taken in Friends Portfolio Private Limited, who never possessed any shares nor demat account.....

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....f challenge in this petition. In the meantime on August 29, 2002, block assessment was done by the Income-tax Department under section 158BC of the Act in the case of Shri Manoj Agarwal in which the above quoted statement has been reproduced. It is interesting to note that Shri Manoj Agarwal has further made a written submission in the block assessment proceedings on June 25, 2002, to the effec....

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.... and his concerns was a step after profits resulted in the case of the above mentioned five transactions. He, therefore, contended that there was no reason for transfer of the petitioner's assessments to New Delhi as it would unnecessarily involve expenditure and inconvenience to the petitioner. He has, therefore, challenged the order of centralisation under section 127 of the Income-tax Act. C....