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2023 (7) TMI 507 - HC - Income TaxAddition u/s 68 - unsecured loans - Discharge of onus or not by assessee? - whether no evidences and material to establish the creditworthiness, genuineness and identities of lenders in the transactions? - Tribunal justification upholding the order of the appellate Commissioner in deleting the addition - HELD THAT:- The findings recorded by the appellate Commissioner as well as the Income Tax Tribunal are based on material and proper appreciation thereof. They are the findings of facts not liable to be interfered with. As noted by Tribunal during the remand proceedings, the details such copy PAN, ledger account and confirmation and other details such as bank statement, audited books were made available before the AO. However, the AO without considering and pointing any deficiency in the above primary document held that the assessee failed to prove the identity of the creditor, explain the genuineness of transaction and establish the credit worthiness of the creditor - No substantial question of law.
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