2025 (11) TMI 1944

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....(3) r.w.s. 147 of the Act on 24-12-2018. The sole issue that fall for our consideration is addition made by Ld. AO for Rs. 268 Lacs on account of alleged accommodation entry. The ground raised by the revenue read as under: - (i) Whether on the facts and circumstances of the case and in law, the Ld. CIT(Appeals) has erred in deleting the addition of Rs. 2,68,00,000/- made on account of accommodation entry as receipt of the assessee from M/s IINFC Ltd. during the year under consideration. (ii) Whether that while deleting the above addition of Rs. 2,68,00,000/-, the Ld. CIT(A) has erred in facts that during the course of search in the case of M/s Indiabulls group on 13.07.2016, it was found that the assessee has made bogus sa....

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....rchases in their respective books of accounts by taking accommodation entries from known accommodation entry providers. During search proceedings, the sample invoices from suspicious entities vis-a-vis invoices of non-suspicions entities were compared which revealed that the invoices issued by suspicious entities had no stamping with respect to receipt of material, checking of material, forwarding to the accounts and date stamp of receipt by procurement department. The invoices of non-suspicious entities had all these details. In settlement applications, the group accepted that it had taken bogus accommodation bills from various parties. During this year, the assessee had supplied material to one of the group entity i.e., IINFC Ltd. and rec....

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....erges from the facts that the assessee has made sales to IINFC Ltd. and offered the same as revenue income. The payment of the supplies has been received through banking channels. The assessee furnished adequate documentary evidences including certificate from Sales Tax authorities regarding genuineness of sales transactions. The assessee's books are subjected to Tax Audit and the assessee has maintained quantitative details of its trading stock. The other documents as furnished by the assessee include ledger extract of IINFC Ltd., copies of invoices bearing complete details, bank statements evidencing receipt of sales proceeds through banking channels, copies of VAT returns, documents evidencing delivery of goods, relevant VAT assessment o....