2026 (5) TMI 1537

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....t. 2. The brief facts of the case are that the assessee had filed his return of income for A.Y. 2014-15 on 14.11.2014 declaring total income of Rs. 19,49,190/-. The case of the assessee was reopened on the basis of information that he had taken accommodation entry of Rs. 59,97,950/- from one Shri Sanjay Tibrewal. The assessment was completed u/s. 147 r.w.s. 144B of the Act on 27.03.2022 at total income of Rs. 79,47,140/-. 3. Aggrieved with the order of the AO, the assessee had filed an appeal before the first appellate authority, which was decided by the learned CIT(A) vide the impugned order and the appeal of the assessee was partly allowed. 4. Now the Revenue is in appeal before us. The following grounds have been taken in this a....

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....ade any transaction of Rs. 59,97,950/- through Shri Sanjay Tiberwal or his concerns and this allegation was out-rightly denied in the submissions made before the AO. However, the AO had ignored the submissions of the assessee and made the addition in a routine and mechanical manner without verifying the facts. The Ld. AR contended that the AO was not correct in making the addition by treating a non-existent transaction as an accommodation entry. He submitted that the Ld. CIT(A) had rightly appreciated the facts of the case and deleted the addition. He, therefore, strongly supported the order of the Ld. CIT(A). 7. We have considered the rival submissions. It is found that the AO had made the addition of Rs. 59,97,950/-, on account of acco....