TaxTMI 
TaxTMI 
2024 (12) TMI 37
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....uance of notice u/s. 148 beyond the period of four years and also challenged the addition of Rs. 99,00,000/- added towards share application money u/s. 68. 3. Before us, ld. Counsel submitted that here in this case the return of income was filed on 29/09/2009 declaring total income of Rs. 1,33,16,240/- and thereafter assessment was completed u/s. 143(3) on 23/12/2011 after making adhoc disallowance of various expenses of Rs. 11,00,000/- and assessment was completed at an income of Rs. 1,44,60,240/-. Thereafter, notice u/s. 148 was issued on 29/01/2013 on account of some alleged bogus purchases and addition of Rs. 3,40,64,343/- was made, adding entire purchase and total income was assessed at Rs. 4,74,24,583/-. Now again second reopening ....
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.... the ld. AO. During the course of assessment proceedings ld. AO noted that assessee has received share application alongwith share premium from following six entities. Sr. No. Name of the shareholder No. of equity Share capital Total capital Share Premium Share Premium Shares Face Value Amount 1. Blazer Venture Pvt. Ltd. 120000 10 1200000 10 1200000 2. Capetown Mercantile Company Pvt. Ltd. 50000 10 500000 10 500000 3. Fairment Venture Pvt. Ltd. 120000 10 1200000 10 1200000 4. Kumaon Engineering Co. Pvt. Ltd. 100000 10 1000000 10 1000000 5. Moto Soft Tel Pvt. Ltd. 55000 10 55....
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....his ground alone reopening should be quashed. 7. On the other hand, ld. DR submitted that it is an undisputed fact that assessee received share application money and could not prove the genuineness and creditworthiness of the parties and once it is a fact that assessee had received credit entries, the reopening is valid. Thus, he strongly relied upon the order of the ld. CIT(A) confirming the reopening. 8. We have heard both the parties and also perused the relevant finding given in the impugned orders. As noted above, here in this case original assessment order was passed u/s. 143(3) on 23/02/2011 and then again re-assessment order was passed u/s. 143(3) / 147 on 03/12/2013, whereby addition was made on some alleged bogus purchases. ....
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....try of Rs. 20,00,000/-, that is, it is in the form of loan, share application money or bogus sales, etc. and which of the companies / entities of Shri Pravin Jain group has provided the accommodation entry to the assessee. There has to be specific material coming on record and correlation with the entries in the book. Here in this case there is no accommodation entry of Rs. 20,00,000/- credited in the books of the assessee, which fact is also borne out from the assessment order. The share application money has come from six entities and without any material information on record as to how these companies were Benami concerns of Shri Pravin Jain or group and how these companies are related to Shri Pravin Jain, can there be any reason to beli....
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....er:- Q.63 Please give the complete list of all the companies in which either you or your close associates/family members are directors along with the complete list of companies under your control Sir, I am a director in the following companies 1. Anchal Properties Pvt Ltd 2. Easy Mercantile Pvt Ltd 3. Nakshatra Business Pvt Ltd 4 Olive Overseas Pvt Ltd 5. Picadily Overseas Pvt Ltd 6. PIM Trading (1) Pvt Ltd 7. Raghunandab Reyons Ltd 8. Riddhi Siddhi Multitude Pvt Ltd 9. Sanjivani Enviro Protection Ltd 10. SBI Training India Pvt Ltd 11 Sumith Commercial Pvt Ltd 12 Spine Infotech Pvt Ltd 13. Angel Softlang Pvt....