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2021 (2) TMI 678 - AT - Income TaxAddition u/s 68 - accommodation entries receipt - Addition on the basis of statements of Shri Mukesh Kumar and Shri Deepak Agarwal found that they have controlled the Investor Company PIPL who have provided accommodation entry to the assessee company - HELD THAT:- Assessee has produced the documentary evidences noted above which clearly shows that the Investor company has made investment in assessee company which is confirmed by the Investor in their confirmation and affidavit of the Director. The balance-sheet of the Investor shows that they have made investment in assessee company and they have sufficient balance to make the investment in assessee company which was made through banking channel. No cash was found to have been deposited in the account of the Investor before making investment in assessee company and actual shares were also allotted to the Investor by the assessee company. Thus, documentary evidences on record have not been rebutted by the A.O. through any evidence or material on record. No independent enquiry has been made against these documentary evidences. Therefore, such documentary evidences clearly supports the explanation of assessee that genuine investment have been made in the assessee company. There is no adverse material available on record against the assessee so as to make the impugned addition and that no investigation have been made by the A.O. on the documentary evidences submitted by assessee, we are of the view that addition is wholly unjustified. We, accordingly, set aside the Orders of the authorities below and delete the addition - Decided in favour of assessee.
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