Addition of difference of share valued and valuation as per IT rules sustained as onus of proof not discharged

Sagitarius Securities Pvt Ltd Vs ITO (ITAT Delhi) ITAT Delhi held that addition of difference between the share valued by the company and value determined as per IT Rules sustained as the assessee failed to discharge his onus of proof. Facts- The appellant company was incorporated in the year 1995 and since then, till date, is not doing any business but is only engaged in providing accommodation entries. The more peculiar fact is that during the year, in spite of zero business activities, the assessee company issued 8 lakhs shares, each of face value of Rs. 10/- to two companies, namely, M/s E...