TaxTMI 
TaxTMI 
2024 (7) TMI 838
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.... issues, therefore, for the sake of brevity, all these appeals of the aforesaid assessee are heard together and being disposed of under this common order. 3. Appeal No. ITA 85/RPR/2024 for the assessment year 2011-12 has been taken up as the lead case and our adjudication and decision therein shall apply, mutatis mutandis to the remaining four appeals pertaining to assessment year 2012-13 to 2015-16. 4. The grounds of appeal raised in the ITA No. 85/RPR/2024 are extracted as under: 1) The order of CIT(A) is illegal, bad in law and void-ab-initio. 2) On facts and in the circumstances of the case and in law, CIT(A) has erred in holding that AO had validly assumed jurisdiction to initiate proceeding u/s 147 in respect of income which was already offered for taxation and as such there was no escapement of income within the meaning of section 147. 3) On facts and in the circumstances of the case and in law, CIT(A) has erred in sustaining/ confirming re-assessment order passed by the AO in spite of the fact that re-assessment order passed by the AO is illegal as much as it has been passed without complying with the rules of natural justice and without fol....
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....cable up to AY 2016-17), decision of Hon'ble Kerala High Court in case of "Bhima Jewellers Vs. CIT in ITA No. 15 of 2021 dt. 25.08.2022", decision of Hon'ble ITAT, Chandigarh Bench in case of "Mahaluxmi Food Industries vs. ITO in ITA No. 711/CHD/2022 cit. 01.06.2023", decision of Hon'ble ITAT, Mumbai Bench in case of "Innovative Construction P. Ltd. vs. ACIT in ITA No. 1084/MUM/2019 dt. 11.12.2020" and decision of Hon'ble ITAT, Cochin Bench in case of "Heera Kerala Developers P. Ltd. Vs. ACIT in ITA No. 243/Coch/2019 dt. 30.06.2022" clearly applicable to the facts of the case brought to his knowledge and by following decision of Hon'ble ITAT, Chennai Bench in case of "Deputy Commissioner of Income Tax Corporate Circle Vs. M/s Shree Karthik Papers Ltd. for A.Y. 2006-07 in ITA No. 325/MDS/2015" which was decided in different context and before issuing CBDT circular no. 11/2019 dated 19.06.2019. 10) The assessee reserves the right to add, amend, or withdraw any ground/grounds of appeal at the time of hearing. 5. Brief facts of the case are that the assessee is a Private Limited company, engaged in production of Ingot moulds using the pig iron, iron scra....
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....in the form of commission income. Moreover, in this case enquiry was also made by the ADIT(Inv.), unit -3(4), Kolkata and an enquiry report was also furnished. In this case it has been noticed by the undersigned that huge chunk of cash was deposited in the bank account of M/s Gitanjali Book Depot (A/c No. 10650500398 with ICICI Bank shyam Bazar, Kolkata) and subsequently transferred to the beneficiary assessee company M/s Mahavir Moulds India Pvt. Ltd., Raipur in the form of accommodation entries after layering these cash through different shell entities M/s Evergrow Suppliers Pvt. Ltd. and M/s Arion Commosales Pvt. Ltd. These concerns M/s Evergrow Suppliers Pvt. Ltd. and M/s Arion Commosales Pvt. Ltd. are dummy, not carrying any business activity and are not found at their given address. Hence, the addition of Rs. 55,00,000/- as unexplained cash credits said addition is confirmed and appeal on this ground is dismissed. 3.2.4 During the appellate proceedings, the appellant company furnished documentary evidence in form of books of account and Profit & Loss Account. It is stated by the assessee that the company has maintained it's book of account on mercantile ....
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....ten submission, along with supporting documentary evidence(s), if any further, the assessee also requested to provide the information / clarification / submission / documents. However, the assessee failed to furnished details regarding purchases bill regarding Shiv Trading Co. Thereafter, another notice issued on 14.12.2023 and fixed the hearing on 27.12.2023, requesting once again to provide the same. Thus, the assessee failed to furnished details regarding purchases bill regarding Shiv Trading Co. 3.3.6 Considering the above discussion, the AO is justified in making bogus purchase from Shiv Trading Co. Hence, the addition of Rs. 50,885/- u/s 69C said addition is confirmed and appeal on this ground is dismissed. 3.4.1 During the appellate proceedings, the appellant company submitted the reply, after examine the related reply and case records. There was a credible information with Ld. AO received by the Investigation Wing, Kolkata in the name of M/S Evergrow Suppliers Pvt. Ltd. And M/S Gitanjali Book Depot. The Ld. AO has recorded proper reason for with reopening the case u/s 147 of the Income Tax Act, 1961. This reopening has been done ....
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....on provided by the other government agencies or Other Wing of the Income Tax Department cannot be held as invalid. Hon'ble Delhi High Court in the case of PCIT Vs Paramount Communication (P.) Ltd. [2017] 79 taxmann.com 409 (Delhi)/[2017] 392 ITR 444 (Delhi) has held that information regarding bogus purchase by assessee received by DRI from CCE which was passed on to revenue authorities was 'tangible material outside record' to initiate valid reassessment proceedings. The SLP filed by the assessee against the said order has been dismissed by the Hon'ble Supreme Court which is reported in [2017] 84 taxmann.com 300 (SC). In similar situation, Hon'ble Gujarat High Court in the case of Aishwarya Dying Mills Pvt Ltd Vs DCIT [2018] 94 taxmann.com 430 (Gujarat) has held that AO's fishing inquiry is valid if he receives certain information from the Investigation Wing and forms an opinion before issuance of re-assessment notice. The SLP of the assessee in this case has been dismissed by the Hon'ble Supreme Court. Hon'ble Gujarat High Court in the case of Amit Polyprints (P.) Ltd. Vs DCIT [2018] 94 taxmann.com 393 (Gujarat) has held that reassessment proceeding....
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....at for approval. [ Refer section 151 (1) of I.T. Act ] In both these years, both the authorities -JCIT & PCIT - have granted approvals. In this case, as per section 151(1), approval should have been granted by PCIT alone but it has been granted by both. It is settled law that if the statute requires something to be done in a particular manner, then such act has to be done in that manner alone and the same cannot be compromised in any manner whatsoever. There is no statutory provision in section 151 that the power which is to be exercised by one authority, that can be exercised by another authority. That sub section (1) and (2) of section 151 are two different provisions. These provisions empower 2 different authorities to exercise their power in 2 different circumstances. Reliance on Hon'ble Mumbai Bench of ITAT, in case of ACIT vs Bharti Axa Life Ins co. where your honor is co-author. [Page 223 to 258 of PB-2] The relevant page is 241, para 4.9.2 Proforma seeking approval in this case is at page no.231 of PB-2 - Read this Hon'ble Mumbai ITAT has held that it is a breach of requirement of section 151 an....
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....t is clear that the reasons recorded by the AO is simply reproduction of the enquiry report of ADIT-Kol. In his own language. * Mere receipt of some information from Investigation wing will not amount to reason to believe that income chargeable to tax has escaped assessment. * The AO is dutybound to make some enquiry of his own in furtherance of the enquiry report received from ADIT-Kol., AND there must be mention of "that enquiry" which the AO has made - in the reasons recorded by the AO. * It is NOWHERE in the reason. * When nothing has been done by AO of his own, then how he has formed any belief or he was satisfied that there is escapement of income. * The crucial link between the information received and formation of belief is missing. * And therefore it is clear cut a case of borrowed satisfaction. * For this, we rely on judgment of our own Bench in case of Shri Tarun Pugalia Jain vs ITO [Page 61-76 of PB-21 - relevant page is 67 & 68, para 9. - read it - your honor is the author of this judgment. * Again Mumbai Bench of ITAT has held that where the AO has merely referred the information received from inv....
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....ot in which huge cash wash deposited and he has seen money transferring from Gitanjali Book Depot to Evergrow suppliers pvt ltd and from Evergrow suppliers to Arion Commosales pvt ltd. * Were bank statements of Gitanjali Book depot, Evergrow suppliers and Arion Commosales available with the AO to form the belief? * If these bank statements were available with the AO after issuance of notice u/s 148, then also the notice u/s 148 is invalid - it is because nothing can be added/substituted in the original reasons recorded. [Hindustan Lever vs R.B. Wadekar 268 ITR 322, page 25-30(29) of PB-2] * AO is alleging that Arion Commosales pvt ltd has received money from Evergrow suppliers pvt ltd and then it has given money to the assessee Mahavir Moulds. * It simply means in the bank statement of Arion Commosales, there is credit entry of Evergrow suppliers and then corresponding debit entry of Mahavir Moulds. * IS IT SO? - Only material available with AO from Kolkata is Page 6 to 24 of PB-1. * FOR AY 2012-13 & AY 2015-16, REFER PAGE NO 2 OF PB-1 - FORMAT FOR GRANT OF APPROVAL - IT IS MENTIONED IN COLUMN 7 THAT AO HAS INVOKED EXP. 2, CLAUS....
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....GE No 2 OF PB-I - FORMAT FOR GRANT OF APPROVAL - IT IS MENTIONED IN COLUMN 7 - THAT AO HAS INVOKED EXP. 2, CLAUSE (a) TO SEC. 147 - IT APPLIES IN A CASE WHERE ASSESSEE HAS NOT FILED ITR. * IN THIS CASE, ASSESSEE HAS FILED ITR AND IT IS ON RECORD. * IT SHOWS NON-APPLICATION OF MIND & CASUAL APPROACH OF THE PCIT GRANTING APPROVAL NON-SUPPLY OF MATERIAL USED AGAINST ASSESSEE TILL COMPLETION OF ASST. * AO used so many materials / enquiry reports etc. against the assessee. * AO did not provide any material / enquiry report to assessee till completion of asst. * AO issued last SCN on 13/12/2018 (Refer page no.65-66 of PB-1) * Nothing was supplied by AO. * Reliance on Mumbai HC - CIT vs Videsh Sanchar Nigam (Page 1-2 of PB- 2) * Mumbai HC - Shodiman Investment (Page 3-12 of PB-2) * PCIT vs V. Ramaiah - Karnataka HC (Page 13-18 of PB-2) * Assessee requested AO supply the reasons/materials etc on 09/01/2019- page no..... PB- 1- after completion of assessment * Non compliance of principle of natural justice CHALLENGE TO INVOCATION OF SECTION 147 IN THIS CASE * Section....
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....en reassessment proceedings is invalid. ON MERITS OF THE CASE * It is on record that assessee has credited Rs. 1.99 crore during FY 10-11 (AY 11-12). * Assessee received commission income from Arion Commosales. * It is for the reason that assessee is a company and require to follow mercantile system of accounting as per Companies Act. * AO cannot presume that there is no income to the assessee during FY 10-11. * AO cannot treat Rs. 1.99 crores in place of Rs. 55 lakhs as unexplained income u/s 68 - only amount credited is 55 lakhs. * Settled law that trading receipts which have been credited in the books of accounts and offered for taxation - cannot be further taxed u/s 68. Judicial pronouncements 1. HARSHIL CHORDIA VS. ITO [ 298 ITR 0349 (RAJSTHAN HC)] [Page 153- 160 of PB] 2. ACIT vs. DEWAS SOYA LTD [ ITA NO 336/1NDORE/2012, INDORE BENCH OF ITAT] 3. CIT vs VISHAL EXPORTS OVERSEAS LTD [ TAX APPEAL NO.2471 of 2009, dt. 03/07/2012, Guj. HC] AO did not reject the books of accounts- No inquiry of any sort was made by AO - He simply rejected the income which the assessee....
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....is issue, it was the submission that statutory provisions allows the respective authority to grant the approval u/s 151 depending upon different circumstances, therefore, such powers cannot be exercised by the authority simultaneously, who is not vested with such authority. On this aspect, Ld. AR placed his reliance on the decision referred to in his written submissions (supra). 10. Another contention raised by the Ld. AR was that the transactions which were taken up by the Ld. AO are as per information received regarding commission income received in the garb of accommodation entries by the assessee from bogus companies, as per the report of ADIT (investigation), Kolkata. It is further alleged by Ld. AR, that the reasons recorded by the Ld. AO are under borrowed satisfaction, the reasons recorded are simply reproduction of the inquiry report of ADIT, Kolkata. Ld. AO had merely received some information from the investigation wing and acted upon the same without making any independent inquiry, which should have been done, so as to form a valid reason to believe that income chargeable the tax has escaped assessment. To substantiate the contention qua the borrowed satisfaction of ....
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....t an inference drawn based on the report from investigation wing, which itself was not having the supporting evidence in the form of bank accounts of the entities who were in the chain for executing such alleged bogus transactions. In order to substantiate the allegation that even the account statement of the M/s Gitanjali Book Depot are not available with the investigation wing, Kolkata, the Ld. AR, further taken us to page no.25 of the paper book, showing a letter from Ld. AO to ADIT(Inv.), Kolkata dated 03.12.2018 requesting for the certain details material for forming of reasons to believe, as discussed (supra). It was the submission that such request of the Ld. AO was responded by the investigation wing on 07.12.2018 i.e., after 09 months from the date of recording of the reasons (dated 26.02.2018), this information supplied by the investigation wing was also lacking the copy of bank statement of M/s Gitanjali Book Depot, therefore, it can be convincing the inferred that such details were not even was there in the possession investigation wing. To fortify such assertion, the Ld. AR, further advanced his argument submitting that since the bank statement of M/s Gitanjali Book De....
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....ssessee chargeable to tax has escaped assessment, however, we find that he had failed to apply his mind to the material/information before him and had reopened the case of the assessee by merely referring to the information that was received by him from CIB. As per the settled position of law, the reopening of a concluded assessment presupposes application of mind by the Assessing Officer to the material/information before him, on the basis of which he arrives at a bonafide belief that the income of the assessee chargeable to tax had escaped assessment. However, in the case before us, the Assessing Officer had merely acted in a mechanical manner on the information that was received by him from the CIB, and without applying his mind to the said information/material had reopened the case of the assessee u/s.147 of the Act. In our considered view, the Assessing Officer by reopening the case of the assessee on the basis of a borrowed satisfaction, had thus, wrongly assumed jurisdiction u/s.147 of the Act, which, thus, on the said count itself on the said count itself cannot be upheld and is liable to be quashed. Our aforesaid conviction is supported by the judgment of the Hon'ble Supre....
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....mpugned accommodation entries that were allegedly stated to have been received by the assessee as a beneficiary. On a careful perusal of the 'reasons to believe', it can safely be gathered that the A.O had merely referred to the information that was received by him from the DGIT(Inv.), Mumbai and had dispensed with the statutory obligation that was cast upon him as regards formation of an independent and a bonafide belief that the income of the assessee chargeable to tax had escaped assessment. As observed by us hereinabove, the A.O by not even referring to the nature of the accommodation entries i.e as to whether they were accommodation entries in the nature of sales or unsecured loans or share application money, which as per the impugned information shared by the DGIT(Inv.), Mumbai were stated to have been received by the assessee as a beneficiary from Shri. Praveen Kumar Jain thus, clearly reveals that he had failed to apply his mind to the material on record to arrive a bonafide reason to believe that the income of the assessee chargeable to tax had escaped assessment. In sum and substance, a perusal of the aforesaid 'reasons to believe' though reveals a reference of the materi....
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....sfaction/belief cannot be a mere repetition of the report of the Investigation wing. As observed by the Hon'ble High Court, the reasons to believe must demonstrate link between the tangible material and the formation of the belief or the reason to believe that the income of the assessee chargeable to tax had escaped assessment. Also, a similar view was earlier taken by the Hon'ble High Court of Delhi in the case of PCIT Vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del). In the case before the Hon'ble High Court, it was observed that the A.O in his reasons to believe after setting out four entries which were stated to have been received by the assessee on a single date i.e 10th February, 2003 from four entities which were termed as accommodation entries, which information was received from the Directorate of Investigation, had therein stated : "I have also perused various materials and report from Investigation Wing and on that basis it is evident that the assessee company has introduced its own unaccounted money in its bank account by way of above accommodation entries." In the backdrop of the aforesaid facts, it was observed by the Hon'ble High Court that it could not be gather....
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....by certain individuals/companies without applying his own mind, he was not justified in invoking jurisdiction under Sec. 147. 9. As observed by us at length hereinabove, the A.O in his 'reasons to believe' in the case of the assessee before us had merely referred to the information that was received by him from the DGIT(Inv.), Mumbai that the assessee as a beneficiary had received accommodation entries from two concerns, and dispensing with even the bare minimum requirement of pointing out the nature of the impugned accommodation entries i.e as to whether they were accommodation entries in the nature of sales or unsecured loans or share application money, on the basis of vague and scanty information and without any further verification, examination or any other exercise had jumped to the conclusion that the income of the assessee in respect of the accommodation entries had escaped assessment for the year in question. Accordingly, in the backdrop of the aforesaid factual matrix it can safely be held that the A.O had blatantly failed to apply his mind to the material available on record for forming a belief that the income of the assessee had escaped assessment. We, thus, ar....
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....jali Book Depot and the assessee company could not be established by the revenue till the completion of the assessment, therefore, it is apparent that the basis for issuance of notice u/s 148 are found to be on incorrect facts. To support this contention, Ld. AR placed his reliance on the judgment from the judgment by the Hon'ble Mumbai High Court in the case of Anita A. Choksey vs. Income Tax Officer, [2019] 411 ITR 207, wherein Hon'ble Mumbai High Court has held as under: "It is a settled position in law that the Assessing Officer acquires jurisdiction to issue a re-opening notice only when he has reason to believe that income chargeable to tax has escaped Assessment. This basic condition precedent is applicable whether the return of income was processed under Section 143(1) of the Act by intimation or assessed by scrutiny under Section 143(3) of the Act. [See Asst. Commissioner of Income Tax v/s. Rajesh Jhaveri Stock Brokers (P) Ltd., (SC) 291 ITR 500 and PCIT v/s. M/s. Shodimen Investments (Bombay) 2018 (93) Taxman.Com 153]. Further, the reasons to believe that income chargeable to tax has escaped Assessment must be on correct facts. If the facts, as recorded in the re....
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....ing such invalid order in appellate proceedings are at nullity. 16. Another argument raised by the Ld. AR was that the Ld. AO made the addition on account of accommodation entries received by the assessee in the garb of commission which were duly recorded in the books of the assessee, however, are such books of accounts of the assessee were not rejected by the Ld. AO while recharacterizing the income of the assessee emanating from the same set of books of accounts. 17. Another allegation by the Ld. AR was that there was breach of principle of nature justice that the requisite information which should have been suo moto provided to the assessee by the Ld. AO, such as, copy of reasons recorded, inquiry reports of ADIT, which were relied upon by the Ld. AO. It was the argument that such information were not provided to the assessee till the completion of the assessment by the Ld. AO. However, after completion of the assessee, the assessee requested for such details through a letter dated 07.01.2019, but nothing was provided by the Ld. AO. Ld. AR placed his reliance on the order of Hon'ble Supreme Court in the case of GKN Dryshaft reported in 259 ITR 19, wherein Hon'ble Apex Cour....
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....47 /148 within the realm of illegal, bad in law and proceedings without valid assumption of jurisdiction. On perusal of the reasons recorded in the instant case, it is evident that the Ld. AO had recorded such reasons with his conviction that the assessee had received certain amounts as commission, in the form of accommodation entries from M/s Arion Commosales Pvt. Ltd., which in turn are remitted by M/s Evergrow suppliers Pvt. Ltd as the same was received from M/s Gitanjali Book Depot. It was the observation of Ld. AO that huge chunk of cash was deposited in the bank account of M/s Gitanjali Book Depot and subsequently transferred to the assessee company through layering of transactions. It is also the observation of the Ld. AO that M/s Evergrow Suppliers Pvt. Ltd. and M/s Arion Commosales Pvt. Ltd are dummy entities, not carrying on any business activity and are not found at their given address. Ostensibly, all such information are emanating from the information forwarded by the ADIT (Inv.) Unit-3(4), Kolkata vide their letter dated 30.01.2018 copy of the same has been placed before us, (extracted supra). It is further brought to our attention that the relevant information qua th....
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....ch was to be looked into was not available with the Ld. AO. Further since the facts are found to be incorrect, which was the basis for reopening assessment, therefore, on that ground also the reopening assessment u/s 147 cannot sustained. 21. We, therefore, in terms of aforesaid observations respectfully following the decision of this tribunal in the case of Shri Tarun Pugalia Jain vs. ITO, wherein various judgments comprises of Anirudh Sinhji Karan Sinhji Jadeja Vs. State of Gujarat (SC), Chetan Rajnikant Shah Vs. ITO (ITAT, Mumbai), PCIT Vs. Meenakshi Overseas Pvt. Ltd. (Delhi HC), PCIT Vs. G & G Pharma India Ltd. (2016) 384 ITR 147 (Del), PCIT Vs. RMG Polyvinyl (I) Ltd. (2017) 396 ITR 5 (Del), CIT Vs. SFIL Stock Broking Ltd. (2010) 325 ITR 285 (Del), CIT Vs. Kamdhenu Steel & Alloys Ltd. & Ors. (2014) 361 ITR 220 (Del), on the issue of borrowed satisfaction and mechanical application of mind without independent inquiry have been exhaustively deliberated upon. Applying the ratio emerging from the aforesaid case laws, to the facts in the present case, admittedly, in the instant case the Assessing Officer had formed a reason to believe that the income of the assessee chargeable t....
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....ansactions are not inconsistency with the facts and circumstances, which are construed and recorded by the Ld. AO in the reasons to believe, therefore, had wrongly assumed jurisdiction u/s.147 of the Act, while initiating the reopening proceedings, which thus, on the said count itself cannot be upheld and the assessment completed in wake of such invalid proceedings is liable to be quashed. 22. Since we have quashed the assessment on the basis of aforesaid observations, therefore, without dealing with the other contentions raised by the Ld. AR, may it be legal or on merits, therefore, the same are left open. Resultantly, ITA No. 85/RPR/2024 of the assessee stands allowed. 23. As the issue involved in all the aforesaid appeals are common, having similar facts and circumstances except the quantum of addition, therefore, our decision in ITA 85/RPR/2024 shall apply, mutatis mutandis on the remaining appeals also i.e., ITA No. 86 to 89/RPR/2024, in terms of our observations hereinabove, thus, ITA No. 86 to 89/RPR/2024 of the assessee are also stands allowed. 24. In combined result, the appeals under consideration in this order i.e., ITA No. 85 to 89/RPR/2024 all are disposed of ....
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.... Sir, The Asstt/Dy. Dircetor of Income Tax, Unit-3(4) Aayakar Bhawan Annexe 2nd Floor, P-13 Chowringhee Square Kolkata-700069 Date: 3.12.2018 Sub: Providing of cash/fund trail in connection with the assessment proceedings of my assessee M/s Mahavir Moulds India Pvt Ltd [PAN-AADCM5764F] for A.Yr 2011-12 to A.Y 201516- Reg. Kidly refer to the above. Certain information has been received from your office in respect of my above named assessee through your letter dt 30.01.2018. The information relates to M/s Evergrow suppliers Pvt Ltd, M/s Gitanjali Book Depot and Arion Commosale's Pvt Ltd and one of the beneficiaries identified is my above named assessee. In the referred letter it has been mentioned that a cash/fund trail has been prepared In this regard. However, the cash trail has not been enclosed with the letter so sent. Therefore, it is requested. to provide the cash trall so prepared in that case so as to make use in the assessment proceedings of my above named assessee. An early response Is requested. Yours faithfully, (Amrit Kuma Income Tax Officer Ward-3(1), Raipur ASSISTANT DIRECTOR OF INCOME TAX (IN....
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....sent to the mall address as appeared In the latest 1.T. Return of Shri Ramyatan Mishra , proprietor of M/s Gitanjali Book Stores but there was no compliance. Total credit of the Bank Statements during the FY 2010-11 and 2011-12 is found as below:- Bank Account No. 106505000398 0015-R28570-050 F.Y. 2010-11 2011-12 2010-11 2011-12 Total Credit Rs. 63,93,390 16,49,124 1,13,97,582 6,321 The Assessee filed his latest IT. Return for the A.Y. 2016-17. From Income Tax Return detalls of Shri Ramyatan Mishra and it was found that the assessee did not file his Income Tax Retum for the AY. 2011-12 and 2012-13. The assessee has filed his 1.T. Return for the A.Y. 2013-14 relevant to A.Y. 2012-13 and on perusal of the said IT. Return, It was found that the assessee shown his total income of Rs. 2,04,430/- which thefades Rs. 1,80,000/- as tuition fee and Rs. 23,700/-. The nature of Banking transaction does not match with the Indome as shown in the 1.T.Return for the AY. 2013-14. Since, the assessee did not file his IT.Rathen for the F.Y. 2010-11 and 2011-12 and there was repeated non compliance from the part of the assesses....
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....) M/S SPARDHA STEEL PVT. LTD. AAJCS2116D ITO WARD 2010-11 28.83 JAMSHEDPUR M/S BANKA BULLIONS PVT. LTD. AAICS6983K 3(1), ITO Ward 9(2), 2013-14 Kolkata 2011-12 37.71 130.00 M'S OM SHREE RUPESH STEEL PVT.LTD. M/S BHOOTNATH FOREX SERVICES PVT. LTD. BRAHM (ALLOYS) LTD. AABCO1816C DCIT Circle 2012-13 6(2), KOLKATA 116.00 2013-14 307.80 AADCB7017Q ITO Ward 9(3), 2013-14 Kolkata 279.00 AACCB4367L DCIT Circle-4, 2013-14 GUWAHATI 100.01 M/S GP GLOBAL INDUSTRIES PVT. AACCG2548J DCIT CIRCLE 2013-14 140.00 ETD. 2(1), RAIPUR M/S MAHAVIR MOULDS INDIA AADCM5764F PVT.LTD. TO WARD 2010-11 3(1), RAIPUR 55.00 2011-12 144.00 2012-13 256,52 2013-14 186.00 2014-15 78.00 Prosecution may be initiated against the entitles facilitating accommodation entries le, the proprietor of M/s Gitanjall Book House, M/s Evergrow Suppliers Pvt. Ltd and M/s Axion Commosales Pvt. Ltd. for falsification of Books of Accounts u/s 277A of the I.T. Act, 1961 (Bhogendra Prasad) ADIT(Inv.), Unit-3(4), Kolkata Document 3 सतà¥à¤¯à¤®à¥‡à¤....