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Your kind support in this matter shall be highly appreciated."

Further correspondence between Sruthi Anvas of Nextgen General Trading LLC and Claire Cain and Ewan Heap of Anglo Manx (Isle of Man) indicated that they were attempting to redraft the agreement between Ballenta Incorporated and Nextgen wherein Ballenta was paying Nextgen an amount of 1 million Euros for certain services in the period 1st April 2015 to 30th March 2016. It showed that not only were Anglo Manx and Ballenta related concerns, but that there was no agreement made before and it was being made now because the bank had blocked the receipt to Nextgen's account in lieu of more supporting documents after the name of Ballenta featured in the Panama Papers. It therefore emanates that the assessee through his entity Nextgen attempted to obtain a backdated agreement between Ballenta & Nextgen though there was no such agreement before and the arrangement of loan funds from Ballenta to his account was a sham. On being confronted with the copy of email correspondence, the assessee ITA Nos.1277 to 1281/Del./2021 ITA Nos.723 & 724/Del./2021 CO Nos.55 to 58/Del/2021 claimed no knowledge stating that they took place under the directions of Tarun Maheshwari.