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2014 (2) TMI 1272 - ITAT AMRITSARUndisclosed cash credit - genuineness of the transaction - creditworthiness of creditor - Held that:- There was no dispute regarding identification. As far as the genuineness of the transaction is concerned, the A.O. never doubted the same, the only reason for making the addition was the A.O. disbelieved the creditworthiness of the creditor, although, the source was duly explained to him, it appears that the A.O. doubted the source of the source. Keeping in view the ratio laid down in S.Hastimal v. CIT reported in [1962 (12) TMI 60 - MADRAS HIGH COURT] wherein held assessee should not be placed upon the rack and called upon to explain not merely the origin and source of a capital contribution but the origin of origin and source of source as well. The difficulty on the part of any assessee to explain a transaction which took place before a decade has to be borne in mind by the department and should under no circumstances be underestimated or taken advantage of by them, we are of the view that the ld. CIT(A) was justified in deleting the additions. - Decided in favour of assessee
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