2026 (9) TMI 1239

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.... 1. On the facts and circumstances of the case, the Ld.CIT(A) has erred in deleting the addition amounting to Rs. 1,55,91,879/- made on account of unexplained money u/s 69A of the Act by ignoring the fact that this was a search related case and main person Shri Lokesh Kumar Khabya and Shri Sourabh Sethi in their statement recorded u/s 132(4) of the Income Tax Act, 1961 has admitted the modus operandi of their working of providing the bogus accommodation entries to various entities through various bank accounts. M/s Aarohi creations LLP is one of the beneficiary entities of the same, which was provided accommodation entry through the assessee. 2. On the facts and circumstances of the case, the Ld. CIT(A) has erred in ignoring the f....

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....oan was outstanding during the year under consideration and the loan was taken in the earlier years. In this regard, he brought to our notice detailed findings of the ld. CIT(A) at page 8 of the appellate order and he heavily relied on the above detailed findings. 4. In the rejoinder, ld. DR objected to the above submissions made by the ld. AR and submitted that the issue under consideration may be remitted back to the AO to appreciate the facts on record. In this regard he relied on the decision of Aarohi Creations LLP, Surat vs. DCIT order dated 19.11.2025. 5. Considered the rival submissions and material placed on record. We observed that the assessee received loan from Aarohi Creations LLP of Rs. 1,50,00,000/- not during the year ....