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2018 (4) TMI 343 - HC - Income TaxTDS u/s 195 - Disallowance u/s 40(a)(ia) - reimbursement of expenses - receiving the amounts and arranging for provisional services connected with the Event - Held that:- The Court is of the opinion that the findings of fact in this regard are conclusive. The lower Appellate Authorities, after considering the submissions, clearly held that the record would indicate that the assessee had no privity of contract with the service provider. Having regard to the overall circumstances, the Court is of the opinion that no substantial question of law arises in this regard. Undisclosed income by way of bogus credits - Held that:- AO conducted a first level inquiry by issuing notices under Section 133(6) of the Act but stopped further inquiry. After obtaining the PAN particulars, bank account details and other particulars relating to the identity of the creditors, the AO did not further exert himself to obtain any information or documents from the concerned banks. In these circumstances, the lower Appellate Authorities correctly inferred that the assessee had discharged the initial burden of establishing the identity of the creditors, the genuineness of the transactions and the credit worthiness of the third party. No substantial question of law
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