Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (2) TMI 780 - AT - Income TaxAddition u/s 68 - assessee had failed to discharge its initial onus to prove the creditworthiness of the investors - CIT-A deleted the addition - HELD THAT:- CIT (Appeals) without going into the details of the Assessing Officer's remand report has simply deleted the entire addition despite there is a difference which appears prima facie proper in respect of approximately ₹ 18 crores. Thus, the CIT (Appeals) has not at all properly verified the details given by the assessee during the appellant proceedings and the Ld. AR also could not point out how the difference has crept into. Merely, submitting the addresses, income tax particulars of debenture holders cannot be termed as sufficient evidence. In fact, the receipt of payment and repayment made through banking channels also reveals that the entire addition of ₹ 156.10 was not properly taken into account by the CIT(A) relating to the difference of ₹ 18 crores. Thus, it will be appropriate to remand back this issue to the file of the Assessing Officer for further investigation/verification of all the evidences produced by the assessee in respect of 110 parties and accordingly pass the appropriate order by following due process of law.
|