2014 (5) TMI 1170

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....(3) of the I.T. Act, 1961 ('the Act' for short, on 03.01.2007. Subsequently, on receipt of information from DDIT (Investment.-2), Udaipur that accommodation entries in lieu of cash in the form of share application money from M/s. Alliance Limited, Mumbai, to the tune of Rs. 5,00,000/- during the period of 2005-06. On the basis of this information the A.O. has initiated action u/s 147 after recording reason u/s 148 of the Act that income to the extent of Rs. 5 lakhs has escaped assessment. The A.O. issued notice u/s 148 of the Act and in compliance thereof the assessee-company made a request to treat the Return of Income [ROI] originally filed on 31.07.2006 disclosing loss, as the return filed in response to this notice. During the re-assess....

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....any is further aggrieved. A second appeal has been filed by raising the following grounds :- "1. The ld. CIT(A) has erred on facts and in law in confirming the action of the A.O. in reopening of assessment proceedings u/s 147 of the I.T. Act, 1961. 2. The ld. CIT(A) has erred on facts and in law in confirming the addition of Rs. 5 lakhs u/s 68 by treating the share capital received from M/s Alliance Intermediatories & Networks (P). Ltd. as bogus 3. The ld. CIT(A) has erred on facts and in law in confirming the addition of Rs. 7,500/- on account of alleged commission expenses incurred on raising the share capital." 2.2 We have heard rival submissions and have carefully perused the entire record. Both the parties have reiterated t....