2025 (6) TMI 1473

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....gainst two separate orders by NFAC, Delhi [hereinafter "the ld. CIT(A)"] dated 22/01/2024 and 29/02/2024 respectively. 2. Since both the appeals have identical set of facts, they are disposed off by this common order for the sake of convenience and brevity. 3. Since the facts are identical, we heard the representatives on the facts of ITA No. 1266/Mum/2024. Briefly stated the facts of the case are that the assessee filed its return of income on 29/09/2012 declaring total income at Rs. 2,19,09,030/-. The return was selected for scrutiny assessment and, therefore, assessment was framed u/s 143(3) of the Act by accepting the returned income of the assessee. 3.1. Subsequently, vide notice dated 30/03/2019 u/s 148 of the Act, the AO sought to....

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....f summons and queries were made with the concerned bank as the narration i.e. incoming and outgoing entries were not being maintained properly that resulted many hindrance to make the trail to find out the ultimate beneficiaries. About hundreds of accounts are linked to one another. The following bank accounts are found to be involved which were used as a conduit either to transfer the fund to the beneficiaries in the guise of loan/advance/share capital or to provide accommodation entry or otherwise. 2.3. Out of the above, as per database of entry operator, it is seen that the above mentioned companies have already been identified as shell companies during various search and survey operation conducted by the investigation wing from which ....

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....ed from the account of M/c Vidarbha Minina Pvt. Ltd. (A/c No. 698705112857 in ICICI Bank Ltd.) to the account of Goldstar Metal Solutions Pvt. Ltd. (A/c No. 698701005033 in ICICI Bank Ltd.). From the account of Mis Vidarbha Mining Pvt. Ltd. (A/c No. 698705112857 in ICICI Bank Ltd.) transferred to the account of Mr. Prem Sarogi (A/c No. 698701005033 in ICIC/ Bank Ltd.). Again, on the same day Rs. 100 lakhs was transferred from Mr. Prem Sarogi (A/c No. 698701005033 in ICICI Bank Ltd.) to M/s Vidarbha Mining Pvt. Ltd. (A/c No. 698705112857 in ICICI Bank Ltd.)." 4. The entire quarrel revolves around two pieces of information. First, received from the office of the DDIT(Inv.), Unit-2(3), Kolkata by which the AO came to know that the parties men....