different companies.
4. In view of the above discussions, it can be concluded that these investing
companies are mere paper/shell companies who have ... Finance Company 2500000
Ltd.
Total 6,00,00,000/-
5. He noted that all the above 15 companies are paper/shell companies who
have
crores from four companies however, the
AO though had observed that these four companies are Shell
companies which are managed and controlled by Shri Ankit ... creditworthiness of
lender companies is doubted and allegation has been made with respect
to the lender companies as Shell companies as to what prevent
companies/paper companies. The
observations made by the Hon'ble Courts on the issue are as under:
a) With regard to identity of shell ... 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
base companies' in
this regard-
"iii) the use of base companies
90. Base company situated in low tax jurisdictions
may be used ... that
company.
91. Various approaches have been used to deal
with such arrangements. For example, a company
that is a mere shell with no employees
parent company
based at Hongkong. This Hong Kong based parent company is 100% subsidiary
of company based at China namely Hareon Solar Technology Company Limited ... assessee company
was done by its parent company at Hongkong who is holding 100% shares of
assessee company. This Hongkong based company is 100% subsidiary
case indicate that the assessee company is
a mere shell company or sham arrangement for treaty shopping.
Thus, he held that in such circumstances ... that the Respondent is not a Fly By Night or a Shell
Company.........."
25. In case of Bid Service Division (Mauritius) Limited
used M/s. Sagar Trade Links Pvt. Ltd.. an alleged
paper/shell company for routing its own funds without
bringing on record any concrete evidence ... ascertained by the DIT, Investigation Wing, Kolkata that 40
paper/shell companies were used by beneficiary companies for
routing their own funds through known entry
used M/s. Sagar Trade Links Pvt. Ltd.. an alleged
paper/shell company for routing its own funds without
bringing on record any concrete evidence ... ascertained by the DIT, Investigation Wing, Kolkata that 40
paper/shell companies were used by beneficiary companies for
routing their own funds through known entry
accommodation entries amounting to Rs.1,78,25,000/- from
shell companies controlled by Jain Brothers. Notice under
Section 148 of the Act was issued ... through the various companies and firms controlled by
them. The names of these companies/firms henceforth
referred to as the shell companies of the Jain
assessee company alleging that
the assessee company is one of 49 companies of S K Jain Group used as
shell companies for illegal transactions ... when there is no conclusive evidence against the company that the assessee
company is a shell company providing accommodation entries.
d. From the perusal
