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9. From the above, the Assessing Officer noted that the profit declared by the
above mentioned so-called investor companies over the years is negligible. Even the
turnover declared by the investor companies is not very significant in most of the
cases. The financials of these companies are typically of accommodation entry
providing companies in whose accounts only huge share capital/premium and
investments are reflected without any worthwhile turnover and profits. The Assessing
Officer, in order to further verify the issue, examined the bank statements of some of
these companies and observed that the statements shows back to back transactions of
same amount, i.e., credit and debit of the same amount on the same date(s) or
following date(s) with no other deposits and transactions. This observation, clubbed
with the fact that the sales and income figures of these investor entities as per their
ITD database details depict too meek a balance sheet to justify such huge fund transfer
transactions in their bank accounts, along with other observations as mentioned clearly
suggests that these accounts belong to various entry providing companies and the same
were utilized to provide accommodation entries to the beneficiaries, i.e., Kandhari
group. According to the Assessing Officer, no investor has been produced by the
assessee group. The assessee failed to furnish any documentary evidence regarding
the existence of such investor. Mere filing of confirmations from parties, according to
the Assessing Officer, does not discharge the onus of the assessee. According to him,
it cannot be believed that investors invests their crores of rupees in a non-listed
company without any return and the recipient company even does not have the
particulars/contact details of such investors. He, therefore, asked the assessee to
ITA Nos.2257 & 1088/Del/2018
establish the identity, credit worthiness and genuineness of the investors who had
subscribed to the share capital of the assessee company. The assessee, in response to
the same, filed various details like confirmation, ITR, assessment particulars, MOA,
audited financial results, bank statements, MCA site data extract of all such investor
companies to establish the identity, creditworthiness and genuineness of such investor
companies. It was submitted that all the investor companies are group companies who
were allotted shares by the assessee company during the relevant period under
consideration. The assessee also filed details of source of source, i.e., the source of
funds received by the said investor companies to establish the identity,
creditworthiness and genuineness of such investment with the assessee company.