TaxTMI 
TaxTMI 
2026 (8) TMI 1268
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....proceedings on the assessee as well as the Galaxy Group, establishes that the assessee alongwith associated entities was indulged in accepting huge cash, out of books, booked bogus expenses, and taking bogus accommodation entries aggregating "routing the unexplained money" in parallel black economy of entire Galaxy Group willingly to evade taxes as per the requirement of beneficiaries. 2. That the Ld. CIT(A) erred in deleting the addition of Rs. 51,50,000/- u/s. 68 of the I.T. Act towards bogus entry on account of payment for transaction on property with the paper entity M/s Ess Bee Cyber Space Pvt. Ltd. non descript company ignoring Investigation Wing findings, books of accounts (Ledger) and statements of operators confirming that....
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....s for fund transfer from various non-descript entities and list of beneficiaries were found. Further summons were issued to directors of various non-descript companies. Most of the directors did not comply with the summons issued to them. AO noted that assessee is amongst the beneficiaries of the accommodation entries from the nondescript entities controlled and managed by Sh. Deepak Agarwal and sh. Himanshu Verma. Documents seized during the search contains information which shows that the assessee has obtained accommodation entry amounting to Rs. 1,00,00,000/- during FY 2017-18 relevant to AY 2018-19 from the entity, M/s Ess Bee Cyber Space Pvt, which is paper /shell company controlled and managed by Sh. Himanshu Verma. Accordingly, after....
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....accommodation entries, thus, the amount of Rs. 1,50,000/- being @3% of Rs. 50,00,000/- was also added to the total income of the assessee u/s. 69C of the Act. 4. In first appeal, the Ld. CIT(A) allowed the appeal of the assessee. Aggrieved, revenue is in appeal before us. 5. Ld. Sr. DR vehemently supported the order of the Assessing Officer and reiterated the contentions raised in the grounds of appeal. 6. On the other hand, Ld. AR of the assessee relied upon the order of the Ld. CIT(A). 7. We have heard both the sides and perused the records. We note that the Assessing Officer made an addition of Rs. 50,00,000/- treating the amount received from M/s Ess Bee Cyber Space Pvt. Ltd. as unexplained credit u/s 68, this addition was m....
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....l buyer or forfeiture of part of the deposit. The assessee has also submitted all corroborative documents including bank statements of M/s Ess Bee Cyber Space Pvt. Ltd., its Income Tax returns acknowledgment, ledger confirmation, and correspondence establishing the bonafide of the transaction. The assessee has also demonstrated that M/s Ess Bee Cyber Space Pvt. Ltd. successfully arranged a real buyer, M/s KOP Machinery Pvt. Ltd., for the said property and the refund of the deposit amount took place in accordance with the agreement. Documentary evidence pertaining to the sale deed and correspondence between the parties were placed on record, firmly establishing a substantive commercial transaction. It was the claim of the assessee that the A....