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2024 (9) TMI 730

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..... he assessee during the year under consideration as unexplained and rightly added u/s 68. We have no hesitation in confirming the addition made u/s 68 for the captioned Assessment years. The contention that the loans have been re-paid during the year under consideration therefore the set off of the same should also be given to the assessee does not hold any water as it has been established that the impugned loans were nothing but accommodation entries and the repayment is also nothing but return of accommodation entries therefore, the money which has been brought in the garb of unsecured loan is nothing but the unaccounted money of the assessee and the repayment of the same does not make any sense. Addition of interest paid on such loans - S .....

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..... bai that Shri Pravin Kumar Jain through a web of concerns run and operated by him is engaged in providing accommodation entries in the nature of bogus unsecured loans, bogus share application etc through various paper entities and the assessee is one of the beneficiaries who has taken accommodation entry. Statement of Shri Pravin Kumar Jain was recorded u/s 132(4) of the Act wherein, he has categorically admitted that the entire business of accommodation entries is through him and Pankaj Jain and companies under their control, which are either owned by him or directly or indirectly controlled are paper companies with no real business transactions. 5. The coordinate bench in the appeal of Praveen Kumar Jain in ITA Nos. 7191/Mum/2018 to 7197/ .....

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..... ment of Sh. Pankaj Kumar Jain recorded on oath u/s 132(4) on 03.10.2013. Q.115 In his statement, Sh Pankaj Jain has clearly stated that he is just a namesake director in various companies run by you. He has not performed any function in those in the capacity of director and his function is restricted to RTGS and cash transfers. Further he has pointed out that there is no genuine business Activity being carried out in those companies. Please comment on the same. Ans. Sir, I fully ageree with the statement of Sh.Pankaj Jain He was namesake director and all companies in which Pankaj is Director are controlled by me Q.116 I am showing you statement of Shri Nilesh Parmar, your employee, recorded on oath u/s 131 of the Income Tax Act, 961 during .....

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..... Picadily Overseas Pvt Ltd 6. PIM Trading (1) Pvt Ltd 7. Raghunandab Reyons Ltd 8. Riddhi Siddhi Multitude Pvt Ltd 9. Sanjivani Enviro Protection Ltd 10 SBI Training India Pvt Ltd 11. Sumith Commercial Pvt Ltd 12. Spine Infotech Pvt Ltd 13. Angel Softlang Pvt Ltd With the following companies and other entities, I am not formally associated but, these are managed and controlled by me Sr.No. Name of Company 1. Aalla Diamond Industries Limited 2. Ansh Merchandise Pvt Ltd 3. Atharv Business Pvt Ltd 4. Bhagyashree Gems Pvt Ltd 5 Casper Enterprise Pvt Ltd 6. Duke Business Pvt Ltd ✓ 7 Flak Trading Co Pvt Ltd 8. Jahanavi Gems Pvt Ltd 9. Javde india Impex Ltd 10. Josh Trading Pvt Ltd 11. Kush Hindustan Entertainment Ltd 12. Pragati Gems Pvt L .....

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..... se circumstances, we are of the considered view that the Assessing Officer as well as Ld.CIT(A have rightly quantified the unaccounted commission earned by the assessees during the year under consideration from 54 companies which is nothing but a huge network of unlawful business to evade the tax for companies operating through them and by the assessee themselves also. Rather, they are in to money laundering. 18. In view of what has been discussed above, we are of the considered view that Assessing Officer as well as Ld.CIT(A) have passed / confirmed legally valid orders to which assessee has failed to controvert by putting in appearance. Assessee has challenged the impugned order passed by Ld.CIT(A) on generic grounds which he has failed t .....

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