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2021 (6) TMI 981 - AT - Income TaxUnexplained cash credits u/s 68 - HELD THAT:- As assessee has filed the documentary evidence pertaining to investor(s) along with confirmation letters claiming to have discharged its onus to satisfy genuineness, credit worthiness of the impugned share capital money It fails to dispute that the legislation has introduced 1st proviso to sec.68 of the Act vide Finance Act, 2012 w.e.f. 1.4.2013 that such a taxpayer must also prove source of source as well (clause “a”) which has remained totally uncomplied with. We make it clear that we are in AY. 2013-14 whereas case law cited before us pertains to AY 1962-63 and upto 2009-10 only. Hon’ble apex court’s judgement in NRA Iron and Steel Corporation Ltd. [2019 (3) TMI 323 - SUPREME COURT] has made it clear that mere filing of documents does not absolve an assessee to prove genuineness and creditworthiness of its investor(s) parties. We thus express our complete agreement with the learned CIT(A)’s detailed findings affirming impugned unexplained cash credits addition - The assessee fails in its sole substantive ground.
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