Mallard Securities Private Limited Vs ITO (ITAT Delhi)
₹305 Crore Addition Stands – ITAT Delhi Confirms Cash Credit & Expenditure Against Mallard Securities No Proof, No Relief – Mallard Securities Fails u/s 68, ₹305 Cr Addition Upheld ITAT Delhi Confirms ₹305 Crore Addition – Mallard Securities Fails to Discharge Onus u/s 68Delhi ITAT dismissed the appeal of Mallard Securities Pvt. Ltd. & upheld additions aggregating to more than ₹305 crore made by AO & confirmed by CIT(A).
Assessment was reopened & framed u/s 143(3)/147 on 20.12.2018. AO made additions of ₹300.03 crore u/s 68 as unexplained cash credits, being amounts credited in books of Assessee without satisfactory explanation & ₹5.40 crore as unexplained expenditure @ 1.8% of alleged accommodation entries.
CIT(A) vide order dated 31.01.2023 confirmed additions, holding that Assessee failed to substantiate its case.
Despite service of notice, no one appeared for Assessee. Tribunal proceeded ex-parte & heard Departmental Representative.
AO issued notices seeking explanation of nature & source of credits. Assessee failed to provide confirmations, identity, genuineness or creditworthiness of parties. AO treated amounts aggregating ₹300.03 crore as unexplained cash credits u/s 68. Additionally, AO estimated unexplained expenditure of ₹5.40 crore being 1.8% of accommodation entries.
CIT(A) held that Assessee did not furnish any documents either during assessment or appeal to discharge its onus u/s 68. Hence, additions were upheld.
