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2022 (12) TMI 433 - ITAT PUNEReopening of assessment u/s 147 - Addition u/s 68 - beneficiary of accommodation entries - loans and advances credited in the books of the appellant company - genuineness of transactions of purchase of shares - appellant deliberately withheld the information from the AO as well as the CIT(A) which is within exclusive knowledge of appellant - HELD THAT:- the appellant had failed to discharge the onus casts upon him to prove the genuineness of the transactions, identity of the creditors and creditworthiness of the creditors/investors who should have financial capacity to make the advance in question to the satisfaction of the Assessing Officer. Therefore, the ratio of the decision of the Hon’ble Supreme Court in the case of NRA Iron & Steel (P.) Ltd. [2019 (3) TMI 323 - SUPREME COURT] is squarely applicable to the facts of the present case. The appellant deliberately withheld the information from the Assessing Officer as well as the ld. CIT(A) which is within exclusive knowledge of appellant to establish the genuineness of transactions of purchase of shares of that company. Following the decision in the case of Hon’ble Supreme Court in the case of Friends Trading Co. [2022 (9) TMI 1076 - SUPREME COURT] with other several decisions, additions confirmed
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