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2022 (2) TMI 863 - AT - Income TaxAddition u/s 68 - unsecured loans treated as unexplained credits - as per AO sole objective of providing accommodation entries and the creditworthiness of these parties along with the genuineness of the transactions have not been proved - directors of these companies were neither produced by the assessee before the AO nor did they present themselves for personal deposition in response to the summons issued u/s. 131 - HELD THAT:- As gone through the details of all the 14 companies which have lent the amounts to the assessee. We have also gone through the details filed by various loan parties before the revenue authorities. After going through the entire details, we hold that the assessee has failed to undisputedly prove the genuineness of the loans or the creditworthiness of the parties. Revenue has also failed to conduct complete enquiries to bring much needed evidences on record. Hence, in the interest of justice to both the parties, we deem it proper to remand the matter to the file of the Assessing Officer with instructions to the Supervisory Officers to act in accordance with the provisions of the Income Tax Act in conducting the enquiries. Needless to say, the revenue shall follow principles of natural justice while concluding the proceedings. Appeal of the assessee is allowed for statistical purposes.
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