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TMI Blog2023 (2) TMI 575X X X X Extracts X X X X X X X X Extracts X X X X ..... companies including the assessee company. Since the assessee company did not provide any satisfactory explanation for the investment made in the form of share application money the AO has rightly made addition. The assessee has only given the details of M/s. Subodhsagar Share Services Pvt. Ltd. that also in the tabular form and not exactly how the funds owned by the assessee. Therefore, the CIT(A) was right in confirm the addition. Hence, appeal of the assessee is dismissed. - I.T.A. No. 421/Ahd/2020 - - - Dated:- 10-2-2023 - MS. SUCHITRA KAMBLE , JUDICIAL MEMBER For the Appellant : None For the Respondent : Shri Ramesh Kumar , JCIT ORDER The appeal filed by the assessee is against the order passed by the Ld. CI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce under Section 148 was issued to the assessee on 31.03.2017 requesting to file its return of income for A.Y. 2010-11 within 30 days from the received of the said notice. The response to the notice the assessee filed return of income on 03.10.2017 showing income at Rs. 24,650/- as per the original return income filed by the assessee on 31.03.2012. The assessee called for reasons for assuming jurisdiction under Section 147 of the Act through letter dated 31.11.2017. The Assessing Officer providing the reasons for reopening of the assessment and assuming jurisdiction under Section 147 of the Act Income Tax Act, 1961. The reason for reopening was that during the year under consideration the assessee company invested in various companies which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt proceedings as well as before the CIT(A) which are reproduced in order of the CIT(A). 7. The Ld. D.R. submitted that the CIT(A) has rightly confirm the addition as the assessee could establish the companies from whom the funds have been received by the assessee. In fact, the identity of allottees were also not established and in respect of evidences of accommodation entires for share capital in other year and / or other companies were also not given during the assessment proceedings. Thus, the Ld. D.R. submitted that there is no need to interfere with the findings of the CIT(A) and the appeal may be dismissed. 8. Heard Ld. D.R. and perused all the relevant material available on record. It is pertinent to note that except for filing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as to receive the share capital in these companies and providing accommodation entries to those beneficiaries who wanted their unaccounted money has to be brought in their books through accommodation entries. In fact, the names of 13 companies reveal in respect of providing the accommodation entries in the garb of unsecured loans share application money. The CIT(A) further observed that the appellant company made investment in the company name M/s. Subodhsagar Share Services Pvt. Ltd. which collected total sum of Rs. 20,81,40,530/- from various companies including the assessee company. Since the assessee company did not provide any satisfactory explanation for the investment of Rs. 46,80,000/- made in the form of share application money t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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