IMPORTANT POINT
Concurrent findings of fact by authorities upheld by single Judge not to be disturbed lightly.

ORDER

Leave granted.

2. The challenge in the present appeal is to the judgment and order dated 20th March, 2012 in Writ Appeal No.1611 of 2008 passed by the Division Bench of the High Court of Karnataka at Bangalore reversing the judgment and order of the learned single judge dated 10th September, 2008 passed in Writ Petition No.10507 of 2007. The learned single judge, it may be noticed, had dismissed the writ petition filed by the Assessee against the revisional order upholding the order of assessment insofar as addition of an amount of Rs. 2,72,19,285/- is concerned, which was claimed by the Assessee as being legally liable for deduction. The learned Commissioner of Income Tax (C.I.T.) in coming to the impugned finding had recorded as follows:

"Regarding the addition relating to trade creditors, the records establish that the assessee has shown sudden in trade creditors without any significant transactions of purchases during the year. Obviously, there cannot be trade creditors without matching transactions. The investigation carried out by the A.O. exposed the modus operandi of the assessee. It is claimed before the A.O. that crop loans were raised in the names or planters within the family circle hailing from Chennai purportedly owning some estates. The loans-raised by them from the bank where the assessee also operated its bank accounts were claimed to be given to the assessee. The investigation further revealed that these crop loan applications were prepared and signed by none other than the top man in the management of the assessee. On top of it, the crop loans accounts in the bank were also operated by the same person from the assessee. When the investigation arm was extended to Chennai and some details were collected about these so-called estate owners, no such accounts appear in their records. Besides, the nexus of their sacrificial loans to bail out the assessee could not be bridged either. In effect, there was clear instance of creation of accounts by way of name leading, a fraudulent practise. All these aspects were fully exposed in the investigation carried out by the A.O. The representative tried to sell the idea that these people are IT payees having proper economic existence. It may be true that these persons are separately assessed to tax, but the nexus of their running estates and their leading financial support could not be substantiated. In my view, there is no cause for interference in the present proceedings to approve the findings of the excellent investigation carried out by A.O."

The aforesaid view was upheld by the learned single judge in the writ petition by observing as follows:

"6. The material on record discloses that the crop loan was raised in the names of planters within the family circle hailing from Chennai purportedly owning some estates. The loans raised by them from the Bank where the assessee also operated its bank accounts were claimed to be given to the assessee. These crop loans applications were prepared and signed by none other than the top man in the management of the assessee. The crop loan accounts in the Bank was operated by the same persons. In the records of the said estate owners, his bank transaction is not reflected. In fact though all those accounts holders are also income tax assessees, the returns did not disclose the payment of the aforesaid amount to the assessee. Even the assessee accounts also did not disclose the receipt of the said amount from those account holders. It is only at the time of investigation when he was asked the source of this income, he pointed out that the said amount has come from transfer of amounts of the very same Bank account. It is in that context, a detailed investigation was made and it was found out that it is a clear instance of creation of accounts by way of name lending, a fraudulent practise. In those circumstances, the revisional authority was justified in rejecting the case of the petitioner and upholding the assessment order. In that vie