Kaane Visionary Projects Private Limited Vs ACIT (ITAT Delhi)
The appeal was filed by the assessee against the order dated 30.06.2025 passed by the Commissioner of Income Tax (Appeals) under Section 250 of the Income Tax Act, 1961, arising from an assessment order passed under Sections 153C read with 153A for Assessment Year 2012-13.
The assessee, a private limited company, had originally filed its return declaring nil income. Proceedings under Section 153C were initiated following a search conducted in the Kuber Group cases under Section 132. During assessment, the Assessing Officer observed that the assessee had received share application money amounting to ₹19,00,47,596 from two entities and had immediately transferred the funds to M/s. Enso Infrastructure Ltd. The Assessing Officer further noted that Shri Ashish Begwani, described as an entry operator, had served as a director in both M/s. Enso Infrastructure Ltd. and M/s. Visionary Infrastructure Projects Pvt. Ltd., from which the assessee had received share application money of ₹5.02 crore. On this basis, the Assessing Officer treated the assessee as a conduit company used for routing accommodation entries and made a protective addition of ₹24,02,47,598 in the assessee’s hands, with the substantive addition proposed in the hands of M/s. Enso Infrastructure Ltd.
