opinions on the aspect that the
pernicious practice of conversion of unaccounted money
through the masquerade or channel of investment in the
share capital ... burden of
proving that the amounts received were unexplained income, or unaccounted
money of the assessee, lay upon the revenue, which it did not discharge
discovered that the
assessee who have unaccounted money ( hereinafter called as entry
takers or beneficiaries ) and want to introduce the same in the books ... have operated
multiple accounts in various branches of banks to introduce unaccounted
money in the guise of gifts, loans, share application money
introduced its own
ITA No. 643/2011 Page 3 of 12
unaccounted money in its bank by way of
accommodation entries. Therefore, I have reasons ... Officer has further recorded that
the assessee company had introduced its unaccounted money in
the bank by way of accommodation entries. In view of what
assessee as share
subscriptions from 15 companies were its own unaccounted monies.
20. We now summarize the findings of the Tribunal as follows ... bank statements
from the companies/Directors for payment of money to the
assessee company as share application money.
(d) The Assessing Officer has not brought
only in the hands of the persons who had given
the said money to these bogus companies for making investment in the form of share ... source from where money has come for investment
by these companies. If after investigation such money is proved to be
unaccounted money, then department
reality
it is the assessee's own unaccounted money which has been
shown in the books of accounts as a receipt from aforesaid
companies
help assessee bring into their booms of accounts their
unaccounted money.
In view of the above facts, I have reason to believe that
the assessee
deduction was not allowed by the AO on his finding that
unaccounted money by way of anonymous donation was used for
the expenditure
interalia deposed that unaccounted
income of various years was invested, benami in the share capital of some ... companies. Shri Kahshinath Shukla, Director of the assessee company, also
introduced unaccounted money benami name as share capital. The details of
these were not known
lead to
the inference that the assessee was trying to introduce
unaccounted money by way of donation receipts. This is
more particularly
