8. In response to the notice, both the lenders have provided similar reply and stated that, it has advanced money to various sister concerns and has also received funds from them. Those details also were subsequently examined by the revenue. According to the revenue, on the examination of those details submitted both by the Assessee as well as the lenders, a position has emerged under which, the revenue has found that the Assessee has been following NIL income ITR since many years, and it filed return of income declaring a sum of Rs.16,400/- in the year under consideration. The comparative table of turnover, purchase, expenses, profit, etc., for Assessment Year 2017-18 and 2018-19 also have been unearthed and stated by the revenue. Therefore, the revenue had come to a conclusion that, the perusal of the said comparative table has made it clear that, it has a typical balance sheet nature with high values of unsecured loans, creditors on liability side and debtors or loans and advances on asset side, therefore, it did not have any significant fixed asset or any capital, and similar trend can be noticed for the prior year also. The revenue also seems to have found that the said lender , namely, Sri Nagalainga Vilas Oil Mill also filed ITR on the total income of only Rs.1,34,580/-, however, it claimed to have given unsecured loan to the Assessee amounting to Rs.41,34,69,610/-.
