TaxTMI 
TaxTMI 
2025 (3) TMI 38
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....ee; therefore, these appeals and COs were heard together and are being disposed off by this common order. 2. The above captioned appeals of Assessment Years(hereinafter, the 'AY') 2012-13, 2013-14, 2014-15, 2015-16& 2016-17 arise against orders dated 24.11.2021 of the Ld. Commissioner of Income Tax (Appeals)-29, New Delhi [hereinafter, the "CIT(A)"]. The assessee has filed COs against all appeals of the Revenue. 3. Grounds taken by the Revenue in appeal of AY 2012-13 and grounds taken in the CO of AY 2012-13, as lead cases, are extracted here under: ITA No. 221/Del/2022, AY 2012-13: "1. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred in deleting the addition of Rs. 13,31,58,724/- made....
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....ring the contention of the assessee that the assessment order was passed alleging that the assessee did not produce director of the assessee company but no such opportunity was provided to the assessee company. 4. (i) On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in rejecting the explanations and evidences brought on record by the assessee to prove the identity and creditworthiness of the lenders and genuineness of the transactions. (ii) That the abovesaid addition has been confirmed ignoring the fact that the addition has been made by the AO without pointing out any defect in the evidences filed by the assessee. 5. On the facts and circumstances of the case, the....
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....hese notices, the assessee filed a letter before the AO requesting to treat the original ITRs as ITRs of the relevant years in compliance to notices under section 153C of the Act. Thus, the income declared in original ITRs remained the same in ITRs of the relevant years in compliance to notices under section 153C of the Act. 4.2 Shri Anand Kumar Jain and Shri Naresh Kumar Jain along with their business concerns & associates(Anand Kumar Jain & Naresh Kumar Jain Entry Operator Group) were searched, on 17.08.2018, under section 132 of the Act. The assessee is one of the companies promoted, controlled and managed by Shri Anand Kumar Jain and Shri Naresh Kumar Jain; Entry Operators, for providing accommodation entries in the garb of share cap....
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.... Rs. 24,56,49,161/- Rs. 23,08,12,351/- and Rs. 10,39,32,748/-in AYs 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17 respectively and taxed the same in the hands of the assessee on substantive basis. Aggrieved, the assessee filed appeals before the Ld. CIT(A), who allowed appeals of the assessee of these years. 5. The Ld. CIT-DR, placing emphasis on the finding of the AO, prayed for upholding of the finding of the AO. 6. On the other hand, the Ld. Authorized Representative (hereinafter, the 'AR') argued that the entire business of providing accommodation entries was controlled and managed by Shri Anand Kumar Jain and Shri Naresh Kumar Jain through their various concerns including the assessee company. It was further submitted that the cre....
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....012- 13 to 2014-15 and 2017-18 6. Third Generation Traders (P) Ltd.; ITA No. 2413 to 2418/Del/2024 for A.Ys. 2012-13 to 2017-18 7. Shivangi Garments (P) Ltd.; ITA Nos. 2186 to 2188/Del/2024 for AYs 2013-14 to 2015-16 8. Round Square Exim (P) Ltd.; ITA Nos 8834 to 8837/Del/2019 for AY 2012-13 to 2015-16 9. Nine Corporate Inception (P) Ltd.; ITA Nos. 189 to 191, 221/Del/2022 for AY 2013-14 to 2016-17 7. We have heard both parties at length and have perused material available on records. We find merit in the submission of the Ld. AR. The Tribunal, in the cases of ZenTradex (P) Ltd. (supra) and Zed Enterprises (P) Ltd. (supra). The coordinate bench of the ITAT, in the case of Zed Enterprises (P) Ltd.: ITA ....
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....operating bank accounts in the names of various concerns/companies through which accommodation entries were being provided and the appellant company was one of such shell concerns. Further the beneficiaries of such accommodation entries were also identified and information to their respective AOs was also disseminated as mentioned in the assessment order as well as the remand report. 14. Having observed so, the ld. CIT(A) held that as far as charging of commission is concerned in the case of the assessee, it has been held by the AO in the assessment order that Sh. Anand Jain and Sh. Naresh Jain were entry operators who were managing and controlling various shell concerns including the appellant for providing accommodation entries i....