PCIT (Central) Vs Kalyanika Infra Mega Ventures Pvt. Ltd. (Madhya Pradesh High Court)
The Revenue filed an appeal under Section 260A of the Income Tax Act, 1961 against the order dated 23/11/2023 passed by the ITAT, Jabalpur in ITA No. 185/JAB/2018 for Assessment Year 2014-15.
The assessee had filed its return on 28/11/2014, declaring total income of nil. Its case was selected for scrutiny and notice under Section 143(2) was issued on 03/09/2015. Subsequently, following a search under Section 132 at the premises of the assessee-company’s Director and other family members, the assessee’s case was centralized under Section 127 by order dated 04/05/2016 and transferred to Central Circle, Jabalpur.
The assessee was engaged in real estate development and related activities. According to the Revenue, various incriminating articles and records were seized during the search and handed over to the Central Circle. However, no search or survey was conducted at the premises of the assessee-company itself.
The assessment was completed under Section 143(3). During assessment proceedings, the Assessing Officer found that the assessee had received credits of Rs.3,68,00,000/- from M/s Little Star Securities Pvt. Ltd., which was stated to be an identified/established bogus company providing accommodation entries. The addition was made on account of unexplained cash credit under Section 68. The CIT(A) confirmed the addition.
