Submission of Basic Documents like PAN & ITR etc doesn’t prove genuineness – Section 263 can be invoked on allegation of accommodation entries
Does the submission of basic documentation sufficiently establish the genuineness and creditworthiness of transactions, thereby precluding the invocation of revisionary powers under Section 263 of the Income-tax Act, 1961?
The Hon’ble Delhi High Court in Principal Commissioner of Income-Tax v. Paramount Propbuild Pvt. Ltd [2025] 482 ITR 61 (Del), held that it does not. The court observed that merely furnishing basic documents such as incorporation details, PAN, or Income-tax returns cannot, by themselves, establish the genuineness and creditworthiness of financial transactions, especially in cases involving shell companies and alleged accommodation entries.
The copy of the order is as under: