Blue Chip Financial Services Private Limited Vs Income Tax (ITAT Mumbai)
ITAT Mumbai allowed assessee’s appeal and deleted addition of ₹20,00,055 made u/s 68, holding that reassessment was based on mistaken identity arising from similarity in names between assessee and another company. AO had treated alleged receipts from Anubhav Commosale Pvt. Ltd. as accommodation entries relying mainly on third-party confirmation and investigation statements.
Tribunal noted that assessee consistently denied any transaction and demonstrated through bank statements that it maintained only one account with Abhyuday Bank where no such entry existed. Documentary evidence from Central Bank of India confirmed that transactions actually pertained to another entity “Blue Chip Financial Consultants Pvt. Ltd.” and not the assessee. Once identity mismatch was established, addition could not survive merely on third-party confirmation.
Holding that assessee cannot be compelled to prove a negative beyond producing available evidence, ITAT deleted the remaining addition sustained by CIT(A) and allowed the appeal in full.
FULL TEXT OF THE ORDER OF ITAT MUMBAI
This appeal filed by the assessee is against the order of National Faceless Appeal Centre (NFAC), Delhi vide DIN & Order No. ITBA/NFAC/S/250/2025-26/1078465141(1) dated 14.07.2025 passed against assessment order u/s. 143(3) r.w.s 147 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated 30.12.2019 for AY 2012-13.
