Allowing the appeal of the revenue the Court held that ; evidence was collected in the course  of search proceedings by the Investigation Wing  it was found that companies were not carrying on any genuine business activities. Directors of these companies were employees of  Mr Tarun Goyal, who were working as peons, receptionists etc. Entries in the books were bogus. Modus operandi in such cases is well known, money is circulated by first depositing cash in the bank account of one such company, and thereupon it is transferred/circulated within the group companies before cheque is issued to the beneficiary. Directors in the course of search proceedings  directors have  admitted that they have signed the documents as per direction of  Mr Tarun Goyal. In response to notice u/s  133(6) details were filed however the respondent-assessee had failed to produce Directors of the companies, though they had filed confirmations, and therefore, were in touch with the respondent-assessee. The respondent-assessee had also failed to produce the details and particulars with regard to issue of shares, notices etc. to the shareholders of AGM/EGM etc- .Accordingly Court held that the transactions are clearly sham and make-believe with excellent paper work to camouflage their bogus nature. The reasoning is contrary to human probabilities. In the normal course of conduct, no one will make investment of such huge amounts without being concerned about the return and safety of such investment. The Tribunal’s order is clearly superficial and adopts a perfunctory approach and ignores evidence and material referred to in the assessment order. Appeal of the revenue was allowed . (ITA No. 49 of 2018, dt. 17.01.2019) (AY.2008-09)