TaxTMI 
TaxTMI 
2026 (3) TMI 541
X X X X Extracts X X X X
X X X X Extracts X X X X
....AO, for short) passed u/s. 143(3)/153C of the Income-tax Act, 1961 (hereafter referred to as 'the Act'). Further details of the orders of the lower authorities are as under: - ITA No. & AY Ld. FAA who passed the appellate order Appeal No. & Date of order of the Ld. FAA AO who passed the assessment order & Date of order 468/D/25 2016-17 CIT(A)-25, Delhi DIN & Order No : ITBA/APL/S/250/2024- 25/1070432443(1) Dated 18.11.2024 DCIT, Central Circle -29 Dated 30.04.2021 469/D/25 2018-19 CIT(A)-25, Delhi DIN & Order No : ITBA/APL/S/250/2024- 25/1070433670(1) Dated 18.11.2024 DCIT, Central Circle -29 Dated 30.04.2021 470/D/25 2017-18 CIT(A)-25, Delhi DIN & Order No : ITBA/APL/S/250/2024- 25/10706057....
X X X X Extracts X X X X
X X X X Extracts X X X X
....come. The AO in the assessment order has observed that Search and Seizure operation u/s. 132 of the Income Tax Act was conducted in the case of Shri Himanshu Verma group in 2012 and subsequently once again on 13.04.2017. On the basis of analysis of seized material found during search, it was found that Shri Himanshu Verma has been providing accommodation entries in the form of unsecured loans/share premium/purchase bills etc. to various beneficiaries through several paper companies managed and controlled by him. The appellant company M/s Seemsan Impex Private Limited is appearing at serial no. 156 in the list of companies listed out by the AO in the assessment order. The AO observed that all these companies managed and controlled by Shri Hi....
X X X X Extracts X X X X
X X X X Extracts X X X X
....e of any corroborative evidence. In any case, the fact remains that the appellant's representative during assessment proceedings filed details and documents in response to notices issued and had submitted that the appellant company was used as a conduit company to provide bogus accommodation entries to beneficiaries. The appellant had neither produced its directors for recording statement u/s. 131 of the Act during assessment proceedings, nor had it available opportunity of cross examination of Shri Himanshu Verma, entry operator. The AO has observed in the assessment order that after accumulation of credits, the same were transferred to the beneficiaries of the accommodation entries. Therefore, the AO assessed commission in th....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ssessments inter alia adding commission income on accommodation entries involving varying sums, as upheld in the lower appellate discussion. It is in this factual backdrop that we sought to know about the corresponding incriminating material found or seized against the assessee during the course of search herein dated 13.04 .2017. 4. Learned CIT-DR takes us to both the impugned assessment orders dated 30.04.2021 that the searched person herein had got recorded his statement that he had around 100 companies including the assessee which provided accommodation entries. He could hardly dispute that no such specific incriminating material found/seized during the course of search herein has been quoted by both the learned lower authoriti....