Dismissing the appeal of the assessee the Tribunal held that ;A private limited co cannot say that it has no clue about the subscribers to its share capital. The genuineness of the transaction has to be determined by ground realities and not by documents like PAN cards, board resolutions, share certificates etc. Even shell cos have these documents. If the assessee is not able to produce the brains behind these companies and the documents with respect to their financials, the transaction cannot be regarded as genuine.Reassessment is held to be valid and addition is confirmed on merit. ( ITA No. 4978/Del/2014, dt. 23.08.2018)(AY. 2005-06)
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