Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (11) TMI 231 - AT - Income TaxAddition u/s 68 - unexplained cash credits of share capital and security premium received during the year - HELD THAT:- Statutory notice u/s. 143(2) of the Act duly served upon the assessee and when the case of the assessee was selected for scrutiny the assessee company having such huge Capital and Security Premium Reserve failed to make any representation before the ld.AO. Even after providing sufficient opportunity by ld.AO no submission was made either before the ld.AO nor before ld. CIT(A) and nor before us. The assessee was asked to explain the cash credits received by it during the year. The assessee failed to file necessary details to explain the source of alleged cash credit and also unable to prove identity, creditworthiness of the shareholders as well as genuineness of the transaction. The assessee company has miserably failed to explain the source of alleged cash credit. If the assessee had sufficient details to explain the alleged sum, it could have certainly filed those details. Consistently escaping from appearing before the ld. AO and the appellate authority (ld.CIT-A) indicates that the assessee has no plausible explanation to explain the source of alleged sum of share capital and security premium. Therefore, the provisions of section 68 of the Act are squarely applicable on the alleged transaction and it can be safely concluded that the assessee had unaccounted income, which has been routed in the books through bogus/accommodation entry in the form of share capital and security premium - Decided against assessee.
|