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2023 (7) TMI 1258 - ITAT RAJKOTAddition u/s 68 - Unexplained cash deposits - ingenuineness of the transactions noting that the three parties had issued cheques to the assessee for advances made from cash deposited in their accounts immediately before the cheques were issued - HELD THAT:- Cash deposits were attributed to loans taken from several farmers who were never verified to the AO - improbability of so many farmers giving loans to these persons was clearly made out by the AO pointing out that all these farmers are residing at a far away Taluka Gondal and had come to Rajkot apparently to open a bank account and to make these cash deposits only for advancing it to these persons. Their bank accounts were also found to be opened in the same bank where these depositors had bank accounts. Even the person introducing the farmers was found to be the director of the assessee-company. The preponderance of probability of such circumstances clearly is that the genuineness of the advances was clearly not established as rightly held by the AO. Advances made to the assessee were suspect and the assessee having failed to discharge its onus of clearing all these suspicions in any whatsoever - be it by producing parties for confirmation or the farmers for confirmation, the AO, we hold that, has rightly held that the cash deposits were unexplained. We, therefore, see no reason to interfere with the order of the learned CIT(A) confirming the addition - Decided against assessee.
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