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2021 (6) TMI 725 - AT - Income TaxAddition u/s 68 - unexplained cash credit - HELD THAT:- As assessee has filed all the details required from these loan creditors for proving the identity and creditworthiness of each of the loan creditors and the genuineness of the transactions. The documents filed are copy of loan confirmation letters, copy of the bank pass books evidencing the fact that the transactions are taken place through banking channels, copy of the income tax returns filed by each of the loan creditors which proves that they are all income tax assessee’s, annual accounts including balance sheet of each of the loan creditors. CIT(A) has discussed each of the documents filed by these loan creditors - He has given factual findings on each of these cash credits. The ld. D/R could not controvert any of these factual findings. AO has issued notices u/s 133(6) of the Act to each of the loan creditors and all these notices were complied with. We uphold the factual findings of the ld. CIT(A) and dismiss this ground of the Revenue. Addition made u/s 2(22)(e) - HELD THAT:- The loan/advance carried an interest of 12% per annum. On these facts, the ld. CIT(A) relied on the decision of Pradip Kr. Malhotra [2011 (8) TMI 16 - CALCUTTA HIGH COURT] as well as CIT vs. Creative Dyeing & Printing (P.) Ltd. [2009 (9) TMI 43 - DELHI HIGH COURT] and deleted the addition. We find no infirmity in the same.
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