9911796707
TMI Blog2024 (6) TMI 860X X X X Extracts X X X X X X X X Extracts X X X X ..... of M/s. Hartron Network Ltd. as well as the intention for obtaining said loan thereby saying that the assessee invested the said amount for acquiring the shares of Kanungo Financers Ltd. the AO doubted the expenses of Kanungo Financers Ltd. but documents and details reveal it otherwise as it is an operational company. As regards, the loss return filed by the M/s. Hartrol Network Ltd., from the perusal of the bank statement and the relevant documents the said company was having sufficient balance to give the loan to the assessee at the particular period. Merely filing the loss return cannot shake the intention of loss return company as they might have reserve funds which in the present is clearly shown in the bank statement as well as its r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -09-2018 and it was found that Shri Rajiv V. Shah has facilitated accommodation entries amounting to Rs.64.44 crores to various beneficiaries. There was regular activity of facility of such accommodation entries by Shri Rajiv C. Shah. In search case of Dharamdev Group, Shri Umang Thakkar admitted that Rajiv C. Shah has provided accommodation entries of Rs. 85.62 crores against unaccounted cash. During Dishman group search case, executive director, Shri Chirag Thakkar accounts Manager, admitted that Shri Rajiv C. Shah has been involved in activity of providing accommodation entries against unaccounted cash/cheque for cash vis- -vis as well. In response to notice u/s. 148 of the Act, the assessee filed return of income on 01- 02-2022 declarin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... RTGS and for which the assessee has filed confirmation, acknowledgement of return of income and bank statement of Hartron Network Pvt. Ltd. to establish the identity of the lender, genuineness of the transaction and creditworthiness of the lender. The assessee has invested the said loan in which the shares in Kanungo Financer Ltd. which are held in demat account of the assessee till date and share of Kanungo Financers Ltd. presently quoted on the BSE. The ld. A.R. further submitted that the said Kanungo Financers Ltd. is a public listed and the findings of the Assessing Officer that it does not exist is not justifiable. The ld. A.R. relied upon the decision of Hon ble Gujarat High Court in case of DCIT vs. Rohini Builders (2002) 256 ITR 360 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... therefore reopening is valid. Thus, ground no. 1 is dismissed. As regards ground no. 2, it can clearly be stated that the assessee has given confirmation of bank statement of M/s. Hartron Network Ltd. as well as the intention for obtaining said loan thereby saying that the assessee invested the said amount for acquiring the shares of Kanungo Financers Ltd. the Assessing Officer doubted the expenses of Kanungo Financers Ltd. but documents and details reveal it otherwise as it is an operational company. As regards, the loss return filed by the M/s. Hartrol Network Ltd., from the perusal of the bank statement and the relevant documents the said company was having sufficient balance to give the loan to the assessee at the particular period. Me ..... X X X X Extracts X X X X X X X X Extracts X X X X
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