2022 (5) TMI 1088

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...., these grounds are dismissed as not pressed. 3. The issue raised in ground no. 5 is against the action of the Ld. CIT(A) in confirmin the addition of Rs.1,27,00,000/- as made by the AO u/s. 68 of the Income-tax Act, 1961 (hereinafter referred to as the "Act"). 4. The facts in brief are that the assessee filed its return of income u/s. 139(1) of the Act which was processed u/s. 143(1) of the Act on 04.11.2010. Thereafter, the case of assessee was reopened on the ground that assessee has taken accommodation entries of unquoted shares by depositing cash belonging to the assessee in the bank account of M/s. Balaji Finance with DCB bank and thereafter, cheque was issued in favour of the assessee. The AO noted that all these purchase and sale ....

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....showing these shares as stock in trade, the details whereof were filed by the assessee at page no. 24A and 24B of the paper book giving details of dates, name of the scripts, quantity and price at which purchase and sold. The Ld. AR also placed before the bench the details of investments held by the assessee as on 31.03.2008, purchased during the year, sold during the year and closing investments as on 31.03.2009. The Ld. AR argued that these shares were sold out of stock in trade held by the assessee and, therefore, there is no question of treating it as accommodation entries. The Ld. AR also submitted that the authorities below have not doubted the investments made by the assessee into these shares in the earlier years as well as in the c....