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2018 (9) TMI 789 - AT - Income TaxAddition u/s 68 - CIT-A deleted the entire additions on the basis of few sample shareholders - Held that:- Assessee has filed confirmation letters of all the 413 persons and during the remand proceedings also, the AO was directed to verify the identity, creditworthiness and genuineness of the transactions. It was the decision of the AO to pick up only 10 persons out of 413 persons and the assessee produced not only these 10 persons but also produced 7 more shareholders. As seen from the remand report reproduced by the CIT (A) AO was satisfied about the creditworthiness of these shareholders for investment in the assessee’s company. AO has not made any adverse comments on the acceptance or otherwise of other 400 people as shareholders, we find that the AO has also not given the breakup of the investment made by the 10 persons or the percentage of investment which has been proved by the assessee to accept the entire investment as genuine. Thus deleting the entire additions on the basis of few sample shareholders is not correct. Therefore, we deem it fit and proper to remand the issue to the file of the AO with a direction to verify the investments atleast to the tune of 25% to 50% and findings on such material may be adopted for coming to any conclusion. - Decided in favour of revenue for statistical purposes.
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