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4. Thus, in the view of above fact, the additional grounds of appeal deserve to be rejected.

5. Further, submissions on the merits of the additions made by the AO are discussed here under:

In the above case the assessee has received an accommodation entry of Rs. 1,75,00,000/- from M/s Khushi Conbuild Pvt. Ltd. which was an entity controlled and oprated by Shri Anand Sharma. These facts have been found by the Investigation Wing Calcutta in its report and also examined by the Assessing Officer in the Assessment order. Ld. CIT (A) after examining the assessment order and replies of the assessee has found that M/s Khushi Conbuild Pvt. Ltd. is a typical case of a shell company and that the said company has no actual business activity (refer Para 6.1 and 6.2 of CIT(A) order. In this regard it is submitted that the Hon'ble Courts on number of occasions have looked at the characteristics of shell companies/paper companies. The observations made by the Hon'ble Courts on the issue are as under:
a) With regard to identity of shell companies, The Hon'ble ITAT, Ahmedabad in the case of MAP Steels (India) Pvt. Ltd. V/S The Dy. Commissioner of Income Tax OSD-1, Circle- Ahmedabad vide ITA. No: 411/AHD/2015 dated 08.02.2018 has made the following observation:-
"Sadly, there is no clear definition of Shell Company in India. However, Securities Act enacted in the USA has defined Shell Company as follows.:
"Securities Act Rule 405 and Exchange Act 12b-2 define a Shell Company as a company, other than an asset-backed issuer, with no or nominal operations; and either: 
     •    no or nominal assets;
     •    assets consisting of cash and cash equivalents; or
     •    assets consisting of any amount ofcash and cash equivalents and nominal other assets."
     In India, Shell Companies haven't in law
12. Though, there Is no definition of Shell Company but anything that throws light on this global menace cannot be brushed aside lightly. The financial statements of Gurukul Vinimay Pvt. Ltd. show that it has all the ingredients of a Shell Company. The appellant company has done transaction with this company and the transaction cannot be accepted as genuine by any stretch of imagination."

c) In the case of our assessee, the Assessing Officer and Ld. CIT (A), after examining the profile of M/s Khushi Conbuild Pvt. Ltd., reached a conclusion that the said company is a paper company without having any real base. In this regard, reference is made to Para 10 to Para 14 of the assessment order and Para 6.1 and 6.2 of Ld. CIT(A) order. Therefore, keeping in view the characteristics of shell companies as discussed above and finding of Ld. CIT (A) regarding this company being a paper/shell company, it is noted that appellant has failed to explain the credits of Rs. 1.75 Crore and therefore the AO was justified to make additions on account of unexplained credits.