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2022 (11) TMI 986 - AT - Income TaxUn-secured credits - non-production of the details of the source of source - Disallowance made Doubting creditworthiness and genuineness of transaction in respect of the source of source - authorities doubted the creditworthiness of this HICSPL, because of the opening balance of HICSPL, the worth of the fixed assets possessed by HICSPL and the details of shareholders and the nature of business not being discussed in the annual report - HELD THAT:- We are of the considered opinion that the non-production of the details of the source of source cannot be dubbed as negligence on the part of the assessee. According to the assessee, all the transactions relating to the creditworthiness of the creditors of HICSPL could be deciphered from the income tax returns and other financial statements furnished now. It is necessary to admit the additional evidence which has a bearing on the issue before us. Since a factual verification is necessary in this matter, which could conveniently be done by AO we set aside the impugned orders and restore the issue to the file to verify the evidence now produced and decide the issue afresh -Grounds are accordingly treated as allowed for statistical purposes.
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