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2023 (6) TMI 1274 - AT - Income TaxAddition of share application money u/s 68 - Valuation of shares u/s 56(2)(viib) - Addition made based on the bank statements and lack of creditworthiness of the applicant parties - CIT(A) held that the assessee has received Part in the earlier years and held that no addition u/s 68 called for in the current year and part amount be treated u/s 56(2)(viib) - HELD THAT:- CIT(A) has not brought out any defect in the methodology and summarily rejected the valuation made under the prescribed rules. Hence, we cannot support the decision of the ld. CIT(A) on this issue. The appeal of the assessee on this ground is allowed. Additions u/s 68 - Low profit ratio - HELD THAT:- With regard to Rs. 9,00,000/- received on 04.09.2014 by the assessee during the year which has been confirmed by the ld. CIT(A) u/s 68, we find that the assessee has discharged his onus before the revenue authorities. AO and the ld. CIT(A) rejected the explanation of the assessee solely based on the limited issue of low profit - There were no enquiries made nor any evidence to reject the documents/evidences filed by the assessee. Hence, we hold that no addition u/s 68 is called for in this case.
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