TMI Blog2000 (10) TMI 182X X X X Extracts X X X X X X X X Extracts X X X X ..... f the case are that assessee raised an aggregate loans of Rs. 52,500 from the undermentioned persons on the date mentioned thereagainst. These loans were repaid on the dates mentioned below: -------------------------------------------------------------- S.No. Name Amount Date of receipt Date of Rs. payment -------------------------------------------------------------- 1. G. Venkateswara Reddy 8,000 7-1-1989 30-1-1989 2. A. Prasada Reddy 8,000 7-1-1989 30-1-1989 3. K. Subba Reddy 10,000 17-8-1988 27-1-1989 4. S. Nagireddy 10,000 17-8-1988 9-9-1988 7,000 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has discharged its onus to prove the credits by filing confirmatory letters. He further argued that since assessment in this case has resulted into ultimate losses and assessee being quite a big firm, there could be no motive for the assessee to introduce small sum of Rs. 45,500 out of its own income and such small loans, therefore, should not have been doubted by the AO in the first instance. Alternatively, he pleaded that the peak credit results into Rs. 33,000 and if at all addition was to be made, it could not exceed Rs. 30,000. He made prayer for the deletion of the addition of Rs. 45,500 in the ultimate argument. 5. On the other hand, learned Departmental Representative relied upon the reasonings given by the authorities below in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... merely filed confirmatory letters in which the alleged creditors have confirmed the fact of loans given to the assessee and the source was explained to be out of their agricultural income. No corroborative evidence has been furnished by the assessee to prove that whether the alleged creditors were having any agricultural land and if they have, whether the quantum of land holding was enough to enable them to save adequate money with them. It has been recorded by the AO in the assessment order that sufficient opportunities were given to the assessee to prove the cash credits. It is not the case of the assessee, at any stage, that opportunity of hearing and to prove the cash credit was not adequate. The case of the assessee is that, by filing ..... X X X X Extracts X X X X X X X X Extracts X X X X
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