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2022 (4) TMI 278 - ITAT RAJKOTAddition u/s 68 - unexplained share capital - HELD THAT:- Before the lowers authorities, assessee has filed copy of the income tax return, PAN numbers of the concerned persons and also filed bank statements. But learned AO doubted the creditworthiness of the concerned persons. In support of its contention, the assessee/persons have not filed all the relevant details before the lower authorities, meaning thereby, the assessee has not discharged his onus. In our considered opinion, the abovesaid details do not prove the creditworthiness of the persons those have paid premium. So, in view of the above, we set aside this matter back to the file of the AO to revisit the issue and assessee is directed to file relevant details of the persons those have paid premium to the extent that they had creditworthiness of such huge payment. The learned CIT(A) has not passed reasoned and detailed order. Therefore, the captioned appeal filed by the Revenue is allowed for statistical purposes.
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