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147. Here in this case, AO in his 'reasons recorded' has referred to information received from ACIT, Central Circle, 22, New Delhi, stating that during survey u/s 133A conducted by the Investigation Wing, Delhi in the case of Shri S.K. Gupta on 20.11.2007, it was gathered that he had floated several companies /firms in which he and his family members as well as employees were providing accommodation entries to the beneficiaries through banking channels to give colour of genuineness of the transactions. In a statement recorded u/s 131, Mr. S.K.Gupta has admitted that he is controlling around 30 companies through which he was carrying out the business of providing accommodation entries to various beneficiaries. From the list of the entries, it was noticed that assessee company too has taken as much 37 accommodation entries. Nowhere from the details mentioned in the 'reasons recorded' it is borne out, what kind of benefit assessee has taken, i.e., whether it pertains to share application money or loan or any other credit entry. The assessee before the AO kept on requesting and asking the AO to provide the relevant material so that it can properly make representation and defend its case. The nature of documents requested by the assessee before the AO has been incorporated above. In response, the AO has only provided statement of Shri S.K. Gupta and some general note which is unsigned and undated of ACIT Central Circle on accommodation entries provided by Shri S.K. Gupta. From the perusal of the statement of Shri S.K. Gupta, it is seen that he has admitted that he was providing accommodation entries, although nowhere there is any mention of assessee's name as beneficiary nor there is any material found from his possession implicating the assessee company has given any money for taking any share application money. The note of ACIT, Central Circle, New Delhi forwarded to the AO was also on the nature of modus operandi adopted by Shri S.K. Gupta for providing accommodation entry. Material found from Shri S.K. Gupta alongwith his statement, can be said to be a relevant piece of material for entertaining reason to believe against the assessee. However, in this case Ld. AO after having received such information should have applied his mind on facts of the assessee company, that is, whether the credit entries pertain to the relevant assessment year; or whether assessee has received any such amount from the entities mentioned in the information. Before the Ld. CIT (A) and also before us, it has been brought on record that there were various defects and discrepancies in the information mentioned in the 'reasons recorded' and the facts of the assessee's case. This implies that there has been absolutely no application of mind by the AO establishing any nexus with the information received and the facts and material pertaining to the assessee.