2026 (2) TMI 496

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....Income Tax Act. 2. The only issue arising for our consideration is whether the Ld. CIT(A) was justified in deleting the addition of Rs.20,00,130/- made by the Assessing Officer under section 69A read with section 115BBE of the Income-tax Act, 1961. 3. Briefly stated, the assessee is an individual and a practising anaesthetist. The return of income was filed declaring total income of Rs.48,87,520/-. The case was selected for complete scrutiny on the basis of information received from the Investigation Wing, Ahmedabad, consequent to a search conducted under section 132 in the case of Shri Sanjay Govindram Aggarwal alias Sanjay Tiberwal, who was stated to be engaged in providing accommodation entries. Relying upon Annexure-A forwarded by....

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....nation. The Ld. AR drew our attention to the fact that the name appearing in Annexure-A was "Kala Enterprises" and not the assessee, and no material was brought on record by the Assessing Officer to establish any nexus between the assessee and the said concern. It was further submitted that the Assessing Officer failed to bring on record any evidence in the form of bank statements, dates of transactions, place of transactions or mode of receipt to establish that the assessee had actually received any accommodation entry. The Ld. AR thus supported the order of the Ld. CIT(A). 6. We have heard the rival submissions and perused the material available on record. We find that the entire addition has been made by the Assessing Officer solely o....