TaxTMI 
TaxTMI 
TaxTMI 
2025 (9) TMI 36
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....hi's order dated 28.08.2024 having DIN & Order No. ITBA/NFAC/S/250/2024-25/1068073741(1) involving proceedings under Section 147 r.w.s. 144 of the Act. 2. 42/Del/2025 for AY: 2014-15 Sh. Ramesh Kumar Bagri ITO, Ward-2(1), Faridabad CIT(A)/NFAC, Delhi's order dated 29.08.2024 having DIN & Order No. ITBA/NFAC/S/250/2024-25/1068124334(1) involving proceedings under Section 147 r.w.s. 144 of the Act. 3. 43/Del/2025 for AY: 2015-16 Sh. Ramesh Kumar Bagri ITO, Ward-2(1), Faridabad CIT(A)/NFAC, Delhi's order dated 29.08.2024 having DIN & Order No. ITBA/NFAC/S/250/2024-25/1068124993(1) involving proceedings under Section 147 r.w.s. 144 of the Act. 4. 44/Del/2025 for AY: 2016-17 Sh. Ramesh Kumar Bagri ITO, Ward-2(1), Faridabad CIT(A)/....
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....in section 147 r.w.s. 144 proceedings against the assessee for the purpose of assessing his entire credits of Rs. 55,17,27,091/- as unexplained for want of his explanation which has been partly extracted to 0.5% in the lower appellate discussion, reading as under: "1. 1. Ground nos.1 Ground number 1 is generic in nature and does not command a separate decision on the same 1. 1. Ground No. 2 Ground number 2 is the material ground which stems from the action of the AO in adding the credit entries appearing in assessee's books as he found them unsubstantiated, more so on account of the fact that no compliances were made at any point of time during the assessment proceedings by the appellant which could aid him to make a more meanin....
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....ffected from them except a copy of ledger, which as per the AO did not match with the books of the assessee. Pertinent be it to mention that no other details were submitted which could enhance the credibility of the transactions. 4. Regarding the sell side, Unitech Ltd acknowledged merely that they used to buy steel from the assessee but the ledger did not match with the one provided by the assessee. 5. The assessee claimed that it had received advance of Rs. 3,00,00,000 from M/s S.V.S Buildcon Private Ltd. The AO issued 133(6) during the remand proceedings but no compliance was made by the entity until the date of submission of the remand report. 6. The AO has also regarded the Police report about loss of documents filed with incredu....
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....n if one assumes that the documents were lost, it is inconceivable that the appellant did not have any access to other supporting documents like way bills, stock register, payment advice etc. The capital base of the assessee is indeed meagre when compared to the turnover. The bank accounts reflect the classic pattern of money and money out. Thus in view of the above the averments of the appellant as being a genuine enterprise do not hold much credence. Furthermore, there was a letter from the DDIT (Inv) Faridabad to the AO during the year 2020-21 in which it was shared that the assessee was an entry provider. The investigation wing was in possession of information relating to the assessee's bank account and the transactions there in and....
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....#39;s income. The AO nis directed to estimate the income at 0.5% of the turnover. Thus the appeal of the assessee on ground no. 2 is partly allowed." 5. It is sufficiently clear that what all the assessee's accounts have witnessed is a continuous flow of credits and debits wherein he has been found to be a mere accommodation entry provider on account of his failure in filing the supportive evidence claiming any genuine business activity. We thus see no reason to interfere with the learned CIT(A) detailed discussion holding the assessee to be an accommodation entry provider in principle. The assessee fails in his first and foremost argument in very terms therefore. 6. Next comes equally important aspect of quantification of the assessee's ....