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2022 (12) TMI 111 - AT - Income TaxRevision u/s 263 - Addition u/s 68 - unexplained cash credits of share capital and share premium received - 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, there was no proper compliance. The assessee failed to produce the alleged parties who had subscribed to the equity shares of the assessee company and did not file any documentary evidence to explain the alleged credit. Assessee was asked to explain the cash credits received by it during the year. Assessee failed to file necessary details to explain the source of alleged cash credit u/s. 68 and also unable to prove identity, creditworthiness of the cash creditors as well as genuineness of the transaction. The assessee company has miserably failed to explain the source of alleged cash credits. If the assessee had sufficient details to explain the alleged sum, it could have certainly filed those details at any stage. Consistently escaping from appearing/producing the documents and alleged parties 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 and, therefore, the provisions of section 68 have rightly been invoked by ld. AO treating the alleged sum as the unaccounted income of assessee, which seems to be routed in the books through bogus/accommodation entry in the form of share capital and security premium. Therefore, we find no infirmity in the finding of the ld. CIT(A) confirming the addition made u/s. 68 of the Act. This ground of assessee’s appeal is dismissed. Disallowance made u/s. 14A - On perusal of order passed u/s.144 of the Act, we find that this addition/disallowance was correctly made as there was no submission/satisfactory explanation. We thus fail to find any infirmity in the findings of the ld. CIT(A). Therefore, we dismiss ground no. 3 raised by the assessee
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