TaxTMI 
TaxTMI 
2026 (3) TMI 1613
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....sessee and deleted the amount of Rs. 65,66,00,955/-. 3. The brief facts of the case are that the assessee is proprietor of M/s ILA International. The AO received information that duringh AY 2014-15, UCO Bank account no. 02400210001387 maintained by the assessee was credited with Rs. 65,66,00,955. Notice u/s. 148 of the Act was issued on 6.4.2021. The assessee filed return of income on 26.11.2022 showing total income of Rs. 764/-. On the basis of the findings recorded in the assessment order, the AO treated the entire amount of Rs. 65,66,00,955/- as unexplained money u/s. 69A and arrived at a total assessed income of Rs. 65,66,01,715/- for the AY 2014- 15. Aggrieved, the assessee preferred the appeal before the Ld. CIT(A)/NFAC, who vide i....
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....oices, Stock register, Payment details, Sales Receipt, Excise Register etc., the entire purchases are required to be treated as bogus. Some sample invoice copies were attached by the appellant along with submissions. From books of accounts, it is seen that the appellant purchased fabric or cloth from KDS Greenland Builders & Promoters Private Limited and Pandit Realtor Private Limited, whereas the same was sold to Sri Banke Behari Builders & Developers and Apex Trading Co. Prima facie, it is suspicious that the appellant is trading in fabric mostly with real estate companies. Hence, the assessing officer rightly presumed that the account was used for the purpose of providing accommodation entries and for routing the money of beneficiaries. ....
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....f the sums so credited. Moreover, entire credits in the bank account were recorded and reconciled with the appellant's books of accounts, submitted during the assessment proceedings. In the case of Aurobindo Sanitary Stores v. CTC (2005) Reported in 276 ITR 549 Orissa High Court held that for applying Section 69, the Assessing Officer must first come to a finding that the assessee made investments which are not recorded in the books of account and thereafter call for an explanation from the assessee about the nature and source of the investments and if he finds that no such explanation was furnished by the assessee firm or the explanation offered by the assessee was not satisfactory, he could treat the value of the investments to be the....
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....information or inquiry or any material that the assessee's company availed any accommodation entry through any entry operator or anyone whereby it has been found that assessee have routed their own unaccounted/undisclosed fund in their books of account. 5.3 Even if the account was used to route accommodation entries, the Bombay High Court has held in the case of Alag Securities Pvt. Ltd (INCOME TAX APPEAL NO.1512 OF 2017) that in these type of activities, brokers are only concerned with their commission on the value of transactions. The high court observed that the action of the Assessing Officer in treating the entire deposits as unexplained cash credits could not be accepted in the light of the fact that the assessee was only....