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2016 (11) TMI 651 - ITAT MUMBAI

2016 (11) TMI 651 - ITAT MUMBAI - TMI - Unexplained cash credit u/s 68 - creditor/subscribers fails to respond to notices - Held that:- Assessing Officer has disbelieved the genuineness of the subscription received by the assessee as share application money, more specifically when the assessee provided the list of share subscribers, their PAN, source of the funds, therefore, mere suspicion is not enough to sustain the addition u/s 68 of the Act. Summons were issued to shares subscribers by the A .....

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The onus cast upon the assessee has been established, therefore, addition cannot be sustained. - AO has not unearthed any wrong or illegal dealing, therefore, he cannot obdurately adhere to his suspicion and treat the subscribed capital as undisclosed income of the assessee. - The Department would not be justified in drawing and adverse inference only because the creditor/subscribers fails or neglect to respond to its notices - Decided in favour of assessee - ITA No.6365/Mum/2011 - D .....

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ct, 1961 (hereinafter the Act). 2. During hearing of this appeal, Shri Hari Raheja, ld. counsel for the assessee, explained that confirmations were filed by the assessee and has no direct relation with Swan Securities, the Directors are not common, the reserves are to the tune of ₹ 1.46 crores besides share capital of ₹ 30.57 lakhs. The profit was declared at ₹ 58.76 lakhs and source of the same is duly explained. The payment were claimed to be through cheque. It was asserted t .....

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ival submissions and perused the material available on record. The facts, in brief, are that from the balance sheet of the assessee company, it was noticed that the assessee has issued ₹ 1,50,000/- fully paid up shares of ₹ 100 each, thereby taking the paid up capital of the assessee from ₹ 60 lakh to ₹ 1,50,00,000/-. The ld. Assessing Officer asked the assessee to furnish the details of share application money received from applicants along with their names address, PAN .....

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of the assessment order) from M/s Swan Securities immediately prior to cheque issued to the assessee for subscription of share capital. In order to verify the genuineness of the transaction, summons u/s 131 were issued to the share applicants and to appear with the details before the Assessing Officer. The stand of the Revenue is that none of the applicants replied to the summons. The ld. Assessing Officer treated the amount of ₹ 78 lakh (Rs.90,00,000- ₹ 12,00,000/-) as unexplained c .....

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sition and analyzed, under the facts discussed hereinabove, as per the provision of 68 of the Act, the assessee has to prove the identity of the share applicant, genuineness of the credit and source thereof. The first and foremost requirement of section 68 of the Act is that the assessee has to prove that the share applicants are existing. In the assessment order, it has been clearly mentioned that pursuant to the summons issued u/s 131 of the Act, nobody attended the proceedings. Meaning thereb .....

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fficer fails to unearth any wrong or illegal dealing, he cannot obdurately adhere is to suspicion and treat the subscribed capital as undisclosed income of the company. If the relevant details of address and identity of subscribers are furnished to the Department along with the copies of the share holder register, share application forms, etc. it would constitute proof or explanation by the assessee and thus the Department would not be justified in drawing an adverse inference only because the c .....

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ment could justifiably be re-opened; and thirdly that the amount of increased share capital could not be assessed in the hands of the company. The later two aspects undeniably possess the character of question of fact. Reference to Section 68 of the Income Tax Act (hereafter referred to as the 'IT Act) is conspicuous by its absence. The Stellar Investment ratio cannot be stretched to the extent that it partakes as a reflection on Section 68, when the enquiry pertained only to Section 263. In .....

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Income Tax (2006) 202 CTR 198 (Guj), to the effect that the dismissal of an Appeal under Section 260A of the IT Act implies that the order of ITAT on the issue stands merged in the Order of the High Court, and for all intents and purposes it is the decision of the High Court which is operative and which is capable of being given effect to. Indeed, this precedent contains a comprehensive and erudite discussion on the question of merger of assailed judgments/orders into the decision of the Appell .....

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not interpret the law in abstraction or in its generality. If the High Court considers it necessary to speak broadly on the law it invariably frames a substantial question of law and thereafter decides it by a judgment in contradistinction to an order. The question before the Bench in Nirma Industries was whether the ITAT could assume a question being open to discussion despite the fact that the High Court had declined to admit the Appeal on that question in respect of that assessed, for a prev .....

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l. In other words, Stellar Investment would have to be restricted to the facts that had occurred strictly in those Appeals and no further. We are in respectful agreement with the understanding of the Division Bench in Commissioner of Income Tax v. Dolphin Canpack Ltd. (2006) 204 CTR (Delhi) 50 as articulated in this sentence - In Steller Investment's case (supra) the issue which the Revenue proposed to raise, related to the propriety of the Tribunal taking resort to s. 263 in the case by ign .....

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more recently in Director of Settlements, A.P. v. M.R. Apparao . The Full Bench of the Patna High Court in Smt. Tej Kumar v. Commissioner of Income Tax (2001) 247 ITR 210 has pithily made a distinction between the dismissal in liming of an SLP and the dismissal of a regular civil appeal by a non-speaking order. The view was that in the former it would not be possible to extract any expression on the legal position on the part of the Court. 5. This analysis, however, does not lead to the consequ .....

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ance Full Bench had not been drawn to the decision of the Supreme Court in C.I.T. Orissa v. Orissa Corporation Pvt. Ltd. (, which if cited would really have left no alternative to the Full Bench but to arrive at the conclusion it did. The Books of Accounts of the assessed contained three cash credits aggregating ₹ 1,50,000/- allegedly received as loans from three individual creditors under Hundis. Letters of confirmation as well as the discharged hundis were produced; but notices/summons s .....

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r index numbers were in the file of the Revenue. The Revenue, apart from issuing notices under section 131 at the instance of the assessed, did not pursue the matter further. The Revenue did not examine the source of income of the said alleged creditors to find out whether they were creditworthy or were such who could advance the alleged loans. There was no effort made to pursue the so-called alleged creditors. In those circumstances, the assessed could not do anything further. In the premises, .....

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Bank transaction details to give some indication of the identity of these subscribers. It may not apply in circumstances where the shares are allotted directly by the Company/assessed or to Creditors of the assessed. This is why this Court has adopted a very strict approach to the burden being laid almost entirely on an assessed which receives a gift. 7. Sumati Dayal v. CIT-Bangalore a succinct yet complete precis on the essentials of income-tax liability can be discerned from these words - In a .....

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present its income; in that case the assessed's version that she had won them through betting on horse racing in two consecutive years did not attract credibility. The Apex Court had followed its earlier decision, namely, Orissa Corporation wherein it had held that since the assessed had given the names and addresses of the creditors, all of whom were income-tax assesses, the failure of the creditors to respond to the Department's notices would not justify an adverse inference being draw .....

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re, the Department ought to have made efforts to pursue these notices/creditors to determine their creditworthiness. These observations sound the death-knell for the contentions raised on behalf of the Department in the present batch of Appeals. 8. Justice B.N. Kirpal (as the learned Chief Justice of India then was) had authored the Order/Judgment both in Stellar Investment and in Sophia Finance. Justice Kirpal's extraordinary experience as the Advocate for the Revenue spanning two decades, .....

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l Bench of this Court in Sophia Finance. 9. In Gee Vee Enterprises the Division Bench had in the context of a challenge to the maintainability of the Writ Petition on the grounds of the availability of an alternative remedy laid down situations which would justify the invocation of Article 226 of the Constitution. The Bench had also opined that the intention of the legislature was to give a wide power to the Commissioner. He may consider the order of the Income-tax Officer as erroneous not only .....

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he Bench held that Section 263 which deals with the Revision of orders prejudicial to the revenue by the Commissioner comes into operation wherever the AO fails to make such an inquiry, because it renders the order of the AO erroneous. It seems to us that if this duty pervades the normal functioning of the AO, it becomes acute and essential in the special circumstances surrounding Section 68 of the IT Act. 10. Returning to Sophia Finance, the Full Bench which was now presided over by B.N.Kirpal, .....

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ng of Section 68 is very wide. The Full Bench opined that - If the shareholders exist then, possibly, no further enquiry need be made. But if the Income-tax Officer finds that the alleged shareholders do not exist then, in effect, it would mean that there is no valid issuance of share capital. Shares cannot be issued in the name of non-existing persons.... If the shareholders are identified and it is established that they have invested money in the purchase of shares then the amount received by .....

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as to whom and to what extent is the onus to show that an amount credited in the books of account is share capital and when does that onus stand discharged. This will depend on the facts of each case. It has been argued, but without substance, that the Full bench did not go further than holding that the only responsibility on the assessed is to identify the subscriber; or that the AO was not required to delve into the creditworthiness of the subscriber; or that the AO need not be satisfied about .....

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ed to the AO not only the names and the particulars of the subscribers of the shares but also their bank accounts and the PAN issued by the IT Department. Super added to all this was the fact that the amount received by the company was all by way of cheques. This material was, in the opinion of the Tribunal, sufficient to discharge the onus that lay upon the assessed. This is evident from the passage extracted from the order passed by the Tribunal earlier. In the absence of any perversity in the .....

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n where the transaction is by cheque where the date and source of the investment cannot be manipulated. 12. The Calcutta High Court has held in CIT v. Precision Finance Pvt. Ltd. that it is not sufficient for an assessed to disclose that credits in their Books had been received through Banking channels; the identity as well as the creditworthiness of the creditor must nevertheless be proved.In Sajan Das and Sons v. Commissioner of Income-Tax (2003) 264 ITR 435 (Del) the Division Bench was not co .....

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ts imprimatur to the inaction of the AO in doing nothing further after the issuance of summons under Section 131 of the Income-Tax Act. It did not condone the AO, failing to issue coercive process, and in this manner attempting incorrectly to shift the burden on the assessed to establish the ligitimacy of the transaction. In Commissioner of Income-Tax v. Antarctica Investment Pvt. Ltd. (2002) 262 ITR 493 (Del) the Court was satisfied that no interference was justified since the assessed had prod .....

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r, the Under Secretary (Land Revenue, Government of Sikkim, Gangtok) had stated that both the subscribing companies were incorporated in Sikkim and their addresses were disclosed in the return of allotments; the subscribers thus stood identified. Their financial standing or capacity was not investigated by the Court. The decision in Commissioner of Income-Tax v. Achal Investment Ltd. (2004) 268 ITR 211 (Del) is also on the same lines. 13. There cannot be two opinions on the aspect that the perni .....

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s financial worth of each of its subscribers. The Company must, however, maintain and make available to the AO for his perusal, all the information contained in the statutory share application documents. In the case of private placement the legal regime would not be the same. A delicate balance must be maintained while walking the tightrope of Section 68 and 69 of the IT Act. The burden of proof can seldom be discharged to the hilt by the assessed; if the AO harbours doubts of the legitimacy of .....

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assessed has prima facie substantiated this fact. In that case one of the creditors had denied the transaction. The Patna High Court in Additional Commissioner of Income-Tax, Bihar v. Hanuman Agarwal was faced with the availability of a confirmatory letter filed by the assessed in whose books of account a credit was found. GIR number of the creditor was supplied, and it appears that he had confessed that this transaction was not genuine. The High Court did not act on the confession since it had .....

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ing its income into capital. 15. In Bharati Pvt. Ltd. v. Commissioner of Income-Tax, West Bengal-I, Calcutta where notices to these alleged creditors had come back unserved, the Division Bench affirmed that the mere filing of confirmatory letters by the assessed did not discharge the onus that lay on the assessed. Different Division Benches of the same High Court have opined that the assessed must prove (a) the identity, (b) the capacity of the creditors to advance money, (c) the genuineness of .....

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ts. However, the Court refused to draw an inference adverse to the assesseds interests. Instead the Calcutta High Court observed that the ITO ought to have investigated the matter more thoroughly to controvert the claim of the assessed, and concurred with the conclusion of the Tribunal that the latter had discharged the initial burden that lay on it. The High Court set aside the decision of the Tribunal which had reversed the findings of the ITO as well as the CIT (Appeals) since the assessed ha .....

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s delivered in March 2003.In Hindusthan Tea Trading Co. Ltd. v. C.I.T. , the Bench opined that in the case of a subscription to the share capital of a company, if Section 68 of the Income Tax Act is to be resorted to, it is necessary for the assessed to prove and establish the identity of the subscriber, their creditworthiness and the genuineness of the transaction. Once material to prove these ingredients are produced it is for the AO to find out as to whether, on these materials, the assessed .....

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ber; (2) the genuineness of the transaction, namely, whether it has been transmitted through banking or other indisputable channels; (3) the creditworthiness or financial strength of the creditor/subscriber. (4) If relevant details of the address or PAN identity of the creditor/subscriber are furnished to the Department along with copies of the Shareholders Register, Shared Application Forms, Share Transfer Register etc. it would constitute acceptable proof or acceptable explanation by the asses .....

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e genuineness of the transaction and the veracity of the repudiation. 17. For a complete understanding of the concept of burden of proof attention should be drawn to decisions delivered in the context of penalty proceeding under Section 271 of the Income Tax Act.CIT, West Bengal v. Anwar Ali [1970] 76 ITR 697 was decided by the Apex Court holding that, if there is no evidence on record except the explanation of the assessed, which explanation has been found to be false, it still does not follow .....

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Act, 1964, intoSection 271 which had deleted the word deliberately in its Sub-section 1(c), thereby shifting the onus of proof onto the assessed, rendering Anwar Ali ineffectual. Nevertheless, in CIT v. Mussadilal Ram Bharose it has been enunciated by the Supreme Court that though the Explanation shifts the burden to the assessed to show absence of fraud, this onus is a rebuttable one. The burden is not discharged by the assessed tendering an incredible or fantastic explanation; and every explan .....

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ting dividends, bonus shares etc. against such share subscriptions unless they are duly claimed by the original subscribers within a prescribed period, perhaps not exceedings three years. Thereafter the shares could automatically stand transferred to the State on the principle of escheat. For these events to happen, requisite amendments to the IT Act may be required. 18. We shall now turn our attention to the facts and details of the present Appeals. The Appeal of the Revenue in respect of Asses .....

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500/- made under Section 68 the assessment was made on this sum. The ITAT noted that the assessed was a Public Limited Company which had received subscriptions to the public issue through banking channels and the shares were allotted in consonance with the provisions of the Securities Contract Regulation Act, 1956 as also the Rules & Regulations of the Delhi Stock Exchange. Complete details appear to have been furnished. The ITAT has further recorded that the AO had not brought any positive .....

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o adopt that reasoning. The ITAT has not articulated its own reasoning in respect of Ground No1 before it viz. deletion of the addition of ₹ 13,05,450/- on account of unexplained shares subscription; whilst it has done so with regard to the other ground viz. deletion of addition of ₹ 9,95,000/- made on account of unexplained loans. The ITAT has categorically held that the assessed has discharged its onus of proving the identity of the share subscribers. Had any suspicion still remain .....

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not be interfered with by the High Court unless it finds it perverse and totally unacceptable. This is especially so with regard to the factual aspects of any Appeal where there are concurrent conclusions of the lower Authorities. The assessed as well as the Revenue had assailed the Order dated 22-2-2002 of the CIT(A) pertaining to the Assessment Year 1989-90. We are presently concerned with the dispute raised by the Revenue relating to the deletion of the addition of ₹ 1,00,18,500/ made b .....

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kim and remarkably at the same address, namely, Dorjee Building, Nam Nang Road, Gangtok. All of them had replied to the Department asking for further time to provide details. The CIT (A) has noted that (a) the stridently adverse findings of the AO at Calcutta had been struck down in Appeal; (b) Notices under Section 143(6) of the IT Act sent to the five Companies were replied to by them; (c) these Companies were duly incorporated under the Sikkimese Companies Act; (d) Assessment of these Compani .....

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partment. The investigations carried out by the AO in Calcutta cannot be relied upon by the AO Bulandsharar consequent on those proceedings being found to be without jurisdiction. While rejecting the assault of the Revenue on this aspect the ITAT has cogently noted that the share capital issued to the original shareholders in the AY 1984-85, which had been cancelled by the AO Calcutta, was found to be valid by the jurisdictional AO at Bulandshashar. But we hasten to clarify that the statement of .....

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e premise for arriving at the conclusion that the renunciation had taken place in a legal manner. We have also noticed that the Rights Issue were picked up only in 1989-1990. These factors are not relevant in these proceedings, even if there have been transgressions to the Companies Act. Support for this approach can be found from The Coco-Cola Export Corporation v. Income Tax Officer . The Apex Court observed that - If any remittance of foreign exchange had been made in excess of the prescribed .....

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ommends application to these proceedings also. In these circumstances we find no scope for interference under Section 260A of the IT Act. This appeal is accordingly dismissed. There shall be no order as to costs. ITA No.953/2006 23. The ITAT has dismissed the Revenue Appeal and thus there are concurrent findings pertaining to the factual matrix. The following paragraph from the impugned decision adequately encapsulates the necessary details: Thus, the question is whether in the present case, the .....

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to the income tax record of the persons who have given the PAN No./Ward No. in order to ascertain the non-existence of the share applicants in question. The AO has neither controverter nor disapproved the material filed by the assessed. In the case of CIT v. Makhni & tyagi (P) Ltd. reported in 267 ITR 433(Del), the jurisdictional High Court has held that when the documentary evidence was placed on record to prove the identity of all the shareholders including their PAN/GIR numbers and filing .....

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he Honble Court has held that when the assessed borrows the loan and if an assessed gives names and address of the creditors, who are assessed to tax and full particulars is furnished then the assessed has discharged the duty. If the Revenue merely issues summons Under Section 131 and does not pursue the matter further, the assessed does not become responsible for the same even if the creditors do not appear. Addition cannot be made under Section 68. No question of law, far less any substantial .....

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had to be framed by March 31, 1999. It has been pointed out that several adjournments had been granted by the Assessment Officer on the asking of the assessed. The timing of the assesseds said letter is most suspect. Generally speaking, it is incumbent on the AO to manage his schedule, while granting adjournments, in such a manner that he does not run out of time for discharging the duties cast on him by the statute. In the present case the details had been furnished to the AO much before March .....

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o the additions made by the AO under s. 68 of the IT Act, 1961 (hereinafter referred to as 'the Act') on account of unexplained share application money is becoming mercurial and mercurial by the day. Though plethora of case law is available deciding various facets of this issue and the principles which are to be applied have almost been crystallized and pumped up by the series of decisions of the apex Court and various High Courts, the issue keeps bouncing back with new dimensions and in .....

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legal position as enunciated in various judgments interpreting the provisions of s. 68/69 of the Act. We may record that this very Bench had the occasion to deal with another batch of appeals touching upon this very issue, which culminated into judgment dt. 31st Jan., 2011 with lead case entitled CIT vs. Oasis Hospitalities (P) Ltd. (2011) 238 CTR (Del) 402 : (2011) 51 DTR (Del) 74 : (2011) 333 ITR 119 (Del). As catena of judgments were taken note of and the ratio culled out therein after undert .....

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s found credited in the books of an assessee maintained for any previous year, and assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the AO, satisfactory, the sum so credited may be charged to income-tax as the income of the assessee of that previous year. 3.As per the provisions of this section, in case the assessee has not been able to give satisfactory explanation in respect of certain expenditure or where any sum is .....

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ough the manner of raising the share capital in the private limited companies, on the one hand and public limited companies on the other hand, would be different. In the case of private limited companies, normally, the shares are subscribed by family members or persons known/close to the promoters. Public limited companies, on the other hand, generally raise public issue inviting general public at large for subscription of these shares. Yet, it is also possible that in case of public limited com .....

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e nature and source of those sums received by the assessee on account of share capital. It is in this scenario, the question arises about the genuineness of transactions. The plain language of s. 68 of the Act suggests that when the assessee is to give satisfactory explanation, burden of proof is on the assessee to provide nature and source of those receipts. 6. What kind of proof is to be furnished by the assessee, is the question. It has come up for discussion in various judgments rendered by .....

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in the share capital of a company and thus stressed upon the duty of the Revenue to firmly curb the same. It was also observed that, in the process, the innocent assessee should not be unnecessary harassed. A delicate balance must be maintained. It was, thus, stressed : 15. There cannot be two opinions on the aspect that the pernicious practice of conversion of unaccounted money through the masquerade or channel of investment in the share capital of a company must be firmly excoriated by the Re .....

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the statutory share application documents. In the case of private placement the legal regime would not be the same. A delicate balance must be maintained while walking the tight-rope of ss. 68 and 69 of the IT Act. The burden of proof can seldom be discharged to the hilt by the assessed; if the AO harbours doubts of the legitimacy of any subscription he is empowered, nay duty-bound, to carry out thorough investigations. But, if the AO fails to unearth any wrong or illegal dealings, he cannot obd .....

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nation preferred by the assessee is found not to be satisfactory, further enquiries can be made by the ITO himself, both in regard to the nature and the source of the sum credited by the assessee in its books of accounts, since the wording of s. 68 is very wide. The Full Bench opined that if the shareholders exist then, possibly, no further enquiry need be made. But if the ITO finds that the alleged shareholders do not exist then, in effect, it would mean that there is no valid issuance of share .....

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n Canpack Ltd. (2006) 204 CTR (Del) 50 : (2006) 283 ITR 190 (Del) and quoted the following observation : . . . credit entry relates to the issue of share capital, the ITO is also entitled to examine whether the alleged shareholders do in fact exist or not. Such an inquiry was conducted by the AO in the present case. In the course of the said inquiry, the assessee had disclosed to the AO not only the names and the particulars of the subscribers of the shares but also their bank accounts and the P .....

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propositions of law in the context of s. 68 of the IT Act. The assessee has to prima facie prove (1) the identity of the creditor/subscriber; (2) the genuineness of the transaction, namely, whether it has been transmitted through banking or other indisputable channels; (3) the creditworthiness or financial strength of the creditor/subscriber; (4) if relevant details of the address or PAN identity of the creditor/subscriber are furnished to the Department along with copies of the shareholders reg .....

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out more, against the assessee; (7) the AO is duty-bound to investigate the creditworthiness of the creditor/subscriber the genuineness of the transaction and the veracity of the repudiation. 10. By this common judgment, the Division Bench decided these appeals of which one appeal related to Lovely Exports (P) Ltd. (supra). Against the said judgment, Special Leave Petition was preferred, which was dismissed by the Supreme Court vide order dt. 11th Jan., 2008 and is reported as CIT vs. Lovely Exp .....

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r individual assessments in accordance with law. Hence, we find no infirmity with the impugned judgment…………. 11. It is clear from the above that the initial burden is upon the assessee to explain the nature and source of the share application money received by the assessee. In order to discharge this burden, the assessee is required to prove : (a) Identity of shareholder; (b) Genuineness of transaction; and (c) Creditworthiness of shareholders. 12. In case the investo .....

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nch held that when the money is received by cheque and is transmitted through banking or other indisputable channels, genuineness of transaction would be proved. Other documents showing the genuineness of transaction could be the copies of the shareholders register, share application forms, share transfer register, etc. 14. As far as creditworthiness or financial strength of the credit/subscriber is concerned that can be proved by producing the bank statements of the creditors/subscribers showin .....

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ogent reasons and materials for the AO and he cannot go into the realm of suspicion. 15. At this stage, we would like to refer to the judgment of the Bombay High Court in the case of CIT vs. Creative World Telefilms Ltd. (in IT Appeal No. 2182 of 2009, decided on 12th Oct., 2009). The relevant portion of this order is reproduced below : In the case in hand, it is not disputed that the assessee had given the details of name and address of the shareholder, their PA/GIR number and had also given th .....

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o the AO. In the above circumstances, the view taken by the Tribunal cannot be faulted. No substantial question of law is involved in the appeal. In the result, the appeal is dismissed in limini with no order as to costs. (Emphasis, italicized in print, supplied) 16. The Court thus clearly held that once documents like PAN card, bank account details or details from the bankers were given by the assessee, onus shifts upon the AO and it is on him to reach the shareholders and the AO cannot burden .....

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urt in the following words : 6. Having heard the learned counsel for the parties, we notice that whenever a company invites applications for allotment of shares from different applicants, there is no procedure contemplated to find out the genuineness of the address or the genuinenity of the applicants before allotting the shares. If for any reason the address given in the application were to be incorrect or for any reason if the said applicants have changes their residence or the notices sent by .....

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the AO in regard to creditworthiness of the shareholders. Once the company had given the addresses of the shareholders and their identity was not in dispute, it was for the AO to make further inquiry. It was borne by the following discussion in the said judgment : 6. The questions raised in this appeal are squarely covered by several judgments of the Supreme Court and also the judgment of this Court passed in ASK Brothers Ltd. vs. CIT, wherein this Court following the judgments of the Supreme C .....

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y to establish but it is for the Department to enquire with the investor about their capacity to invest the amount in the shares. Therefore, we are of the view that the substantial questions of law framed in this appeal are to be answered against the Revenue and in favour of the assessee. Accordingly, this appeal is dismissed. 18. Rajasthan High Court had an occasion to deal with the submission of the Revenue predicated on Benami transactions in the case of CIT vs. AKJ Granites (P) Ltd. (2007) 2 .....

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t the fact that share applications were received from different places accompanied with share application money, no presumption can be drawn that same belong to the assessee and cannot be assessed in his hands as his undisclosed income unless some nexus is established that share application money for augmenting the investment in business has flown from asssessee's own money. In coming to this conclusion, the Court relied on CIT vs. Steller Investment Ltd. (1991) 99 CTR (Del) 40, which has si .....

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ers in accordance with law and, thus, not remediless. It is, thus, for the AO to make further inquiries with regard to the status of these parties to bring on record any adverse findings regarding their creditworthiness. This would be more so where the assessee is a public limited company and has issued the share capital to the public at large, as in such cases the company cannot be expected to know every detail pertaining to the identity and the financial worth of the subscribers. Further initi .....

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ifts from one common donor. The payments were made to them by instruments issued by foreign banks and credited to the respective accounts of the assessees by negotiations through bank in India. The evidence indicated that the donor was to receive suitable compensation from the assessees. The AO held that the gifts though apparent were not real and accordingly treated all those amounts which were credited in the books of account of the assessee, as their income applying s. 68 of the Act. The asse .....

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ns assigned by the Tribunal were in the realm of surmises, conjectures and suspicion. On appeal to the Supreme Court, the Court while reversing the decision of the High Court held that the findings of the AO, CIT(A) and the Tribunal were based on the material on record and not on any conjectures and surmises hat the money came by way of bank cheques and was paid through the process of banking transaction is not by itself of any consequence. The High Court misdirected itself and erred in disturbi .....

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by the assessee, in the opinion of the AO, is not satisfactory. It is only then that the sum so credited may be charged o income-tax as the income of the assessee of that previous year. The expression "the assessee offers no explanation means the assessee offers no proper, reasonable and acceptable explanation as regards the sums found credited in the books maintained by the assessee. The opinion of the AO for not accepting the explanation offered by the assessee as not satisfactory is requ .....

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. The burden is on the assessee to rebut the same, and, if he fails to rebut it, it can be held against the assessee that it was a receipt of an income nature. The burden is on the assessee to take the plea that even if the explanation is not acceptable, the material and attending circumstances available on record do not justify the sum found credited in the books being treated as a receipt of income nature. 22. We would like to refer to another judgment of the Division Bench of this Court in th .....

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sessee under s. 68 of the Act. 23. It is also of relevance to point out that in CIT vs. Steller Investment Ltd. (2000) 164 CTR (SC) 287 : (2001) 251 ITR 263 (SC) where the increase in subscribed capital of the respondent company accepted by the ITO and rejected by the CIT(A) on the ground that a detailed investigation was required regarding the genuineness of subscribers to share capital, as there was a device of converting black money by issuing shares with the help of formation of an investmen .....

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ould be para No. 3 but it is marked as para No. 24-Ed.] 24. It is, thus, clear that initial burden lies on the assessee to explain the nature and source of the share application money received by the assessee. It is also clear that the assessee has to satisfactorily establish the identity of the shareholders, the genuineness of the transaction and the creditworthiness of the shareholders The manner in which such a burden is to be discharged has been explained in various judgments and noted by us .....

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sumes importance at this stage is as to what the Revenue is supposed to do to dislodge the initial burden discharged by the assessee and to throw the ball again in the assessee's court demanding the assessee to give some more proofs, as the documents produced earlier by the assessee either become suspect or are rendered insufficient in view of the material produced by the Department rebutting the assessee's documentary evidence. This is the aspect which has to be gone into in all these c .....

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Since the assessee, though tried to explain the genuineness of the credit on the basis of letters of confirmation, it could not be explained as to how the transaction was materialized when the companies were not in existence and the amount was paid by cheque only on the date on which the amount was credited to the account of the company. It was for the assessee to discharge this burden…………" (B) Calcutta High Court in CIT vs. Kundan Investment Ltd. (2003) 182 CTR .....

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e has to take appropriate steps for proving its case. Unless there are sufficient materials after such communication, produced by the assessee, the ITO can do no further." (C) This Court in CIT vs. Sophia Finance Ltd. (1993) 113 CTR (Del)(FB) 472 : (1994) 205 ITR 98 (Del)(FB), dealt with the issue as under : "………..As we read s. 68 it appears that whenever a sum is found credited in the books of account of the assessee then, irrespective of the colour or the nature .....

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Secondly, depending upon the facts of each case, the ITO may even be justified in trying to ascertain the source of the depositor, assuming he is identified, in order to determine whether that depositor is a mere namelender or not. Be that as it may, it is clear that the ITO has jurisdiction to make enquiries with regard to the nature and source of a sum credited in the books of account of an assessee and it would be immaterial as to whether the amount so credited is given the colour of a loan o .....

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ex Court, the only conclusion which could be arrived at is : (i) that there is no distinction between the cash credit entry existing in the books of the firm whether it is of a partner or of a third party, (ii) that the burden to prove the identity, capacity and genuineness has to be on the assessee, (iii) if the cash credit is not satisfactorily explained the ITO is justified to treat it as Income from 'undisclosed sources', (iv) the firm has to esta lish that the amount was actually gi .....

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firm and in all cases it has to be assessed as an undisclosed income of the partner alone. In these circumstances, we are of the view that the Tribunal was not justified in holding that the cash credits of ₹ 11,502 in the account of Shri Kishorilal, one of the partners, could not be assessed in the hands of the firm and in deleting the same. Since the matter was not considered by the Tribunal on the merits, the Tribunal would be free to hear the arguments of both the parties and decide afr .....

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ffect, by the creditor, on record. Considering these facts, we find that the finding of the Tribunal in this regard is perverse. The assessee has failed to prove the genuineness of the cash credit…… " 25. Following dicta of the apex Court judgment in Sumati Dayal vs. CIT (1995) 125 CTR (SC) 124 : (1995) 214 ITR 801 (SC) was heavily relied upon by the Revenue : "It is no doubt true that in all cases in which a receipt is sought to be taxed as Income, the burden lies upon t .....

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t previous year if the explanation offered by the assessee about the nature and source thereof is, in the opinion of the AO, not satisfactory. In such a case there is, prima facie, evidence against the assessee, viz. the receipt of money, and if he fails to rebut it the said evidence being unrebutted, can be used against him by holding that it was a receipt of an income nature. While considering the explanation of the assessee the Department cannot, however, act unreasonably. ……&he .....

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ch to the problem. The matter has to be considered in the light of human probabilities………….." (Emphasis, italicised in print, supplied) 26. With this discourse on the legal position, we advert to the cases at hand. In these appeals, there is a common thread which runs through all these cases insofar as nature of transaction is concerned. As would be seen when we discuss the facts of this case, the share applicants are all companies incorporated under the Ind an C .....

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funds were transferred by way of credit entries, deposits in the accounts of such applicants, etc. by furnishing such kinds of proofs/documents, the assessees have been able to discharge their initial burden. Notwithstanding the same, as per the AO(s), the applicants were bogus companies which were only paper companies and there is no real existence. In certain cases, it was also found that just before issuing the cheques by the applicants towards share applicant money, cash was deposited in th .....

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2 of 2009 28. In the case of this assessee, we are concerned with the asst. yr. 2004-05. While scrutinizing this case, the AO found that the balance sheet revealed that during the period relevant to the year under assessment, the assessee had received share application money of ₹ 2.74 crores from various applicants. The assessee filed details of all the share applicants and the amounts received along with their confirmation and copies of the bank accounts of such investors from as many as .....

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cants, they had deposited cash for specific purpose for applying for shares in addition to providing entry to the assessee, the same modus was adopted in the other cases as well. (ii) Many companies did not exist at the addresses furnished. The registered letters sent to them had been received back undelivered. (iii) There were reports of the Inspectors (IT) that many parties were not genuine assessees and were not in existence. 29. The assessee had given reply to the said questionnaire in which .....

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sh in their accounts before investing by cheques. 8.AO's remarks "not a genuine taxpayer" are of the Department and the share applicant in which the assessee has no role to play. 9.The assessee has no means to produce the shareholders physically. 10.The postal remarks on the communications to the share applicants were not made available to the assessee company. 11.The report of the Directorate is one sided. 12.The proposal of the AO to t eat the credits received as share applicatio .....

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as also deposited by these companies just before issuing the cheques. The fact that the assessee had showed its inability to produce them was also viewed against the assessee. The AO relied upon the report of the Directorate of the IT (Inv.) which had concluded that all these companies were bogus companies floated by one Mr. Mahesh Garg, who was master behind it, with intent to provide entries. He inter alia observed : "The assessee company has complied with elementary requirements by filin .....

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een deposited in the accounts of the share applicants before being transferred to the account of the assessee company. This anomaly is almost universal except in a few cases where transfer entries have been rotated. In certain other cases both cash has been deposited and entries rotated. The claim of the assessee that he was unaware of this state of affairs is much too difficult to digest. In the light of this fact, other contentions of the assessee company in its representation dt. 17th Nov., 2 .....

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note' on accommodation entries' as prepared by the Directorate of IT (Inv.), the gist whereof is noted above as recorded in the orders of the AO. In the light of the aforesaid, Mr. Sahni referred to the judgments on onus which have also been taken note of above by us. 32. Before we deal with the same, let us find out the raison d'eter behind the orders of the Tribunal in deleting the addition, as CIT(A) had confirmed the orders of the AO agreeing with his reasons. The order of the T .....

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mp; Finance Ltd. (supra), referred to supra, is in regard to SLP filed by the Revenue against the order of Hon'ble jurisdictional High Court and the Hon'ble Supreme Court has specifically with a speaking order dismissed the SLP. The Hon'ble Supreme Court in the various decisions referred to by the learned Authorised Representative has categorically held that the addition in regard to the share capita cannot be treated as the undisclosed income of the assessee if the share application .....

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ve the means to investment but the investment made by the appellant should be shown to have emanated from the coffers of the assessee so as to enable it to be treated as undisclosed income of the assessee. It is noticed that the Revenue has not been able to specifically show that the investments had emanated from the coffers of the assessee in this case. In these circumstances, respectfully following the decision of the Hon'ble jurisdictional High Court as also Hon'ble Supreme Court refe .....

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given under s. 151(1) r/w s. 153(3) of the IT Act." 33. What does follow from the aforesaid ? It is not in doubt that the assessee had given the particulars of registration of the investing/applicant companies; confirmations from the share applicants; bank accounts details; shown payments through account payee cheques, etc. As stated by us in the beginning, with these documents, it can be said that the assessee has discharged its initial onus. With the registration of the companies, its ide .....

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account of these investment companies. 35. The important question which arises at this stage is as to whether on the basis of these facts, could it be said that it is the assessee which has not been able to explain the source and receipt of money. According to the assessee, he had given the required information to explain the source and was not obligated to prove source of the money. It is the submission of the assessee that even in case there is some doubt about the source of money in giving in .....

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received back undelivered, the AO presumed that these companies did not exist at the given address. No doubt, if the companies are not existing, i.e., they have only paper existence, one can draw the conclusion that he assessee had not been able to disclose the source of amount received and presumption under s. 68 of the Act for the purpose of addition of amount at the hands of the assessee. But, it has to be conclusively established that the company is nonexistence. 36. The AO did not bother t .....

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income tax No effort was made to examine as to whether these companies were filing the IT returns and if they were filing the same, then what kind of returns these companies were filing. If there was no return, this could be another factor leading towards the suspicion nurtured by the AO. Further, if the returns were filed and scrutiny thereof reveals that such returns were for namesake, this could yet another be contributing factor in the direction AO wanted to go. Likewise, when the bank stat .....

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r namesake. We say so with more emphasis because of the reason that normally such kind of presumption against the assessee cannot be made as per the law laid down in various judgments noted above. Just because of the creditors/share applicants could not be found at the address given it would not give the Revenue a right to invoke s. 68 of the Act without any additional material to support such a move. We are reminding ourselves of the following remarks of a Division Bench of this Court in its de .....

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hat the assessee need not to prove the 'source of source'. (Emphasis, italicized in print, supplied) 37. We are conscious of the malice of such kind of pernicious practice which is prevalent. In CIT vs. Divine Leasing & Finance Ltd. (supra), this Court had eloquently highlighted the same in the following manner : "There cannot be two opinions on the aspect that the pernicious practice of conversion of unaccounted money through the masquerade or channel of investment in the share .....

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he AO for his perusal, all the information contained in the statutory share application documents. In the case of private placement the legal regime would not be the same. A delicate balance must be maintained while walking the tight-rope of ss. 68 and 69 of the IT Act. The burden of proof can seldom be discharged to the hilt by the assessee; if the AO harbours doubts of the legitimacy of any subscription he is empowered, nay duty bound. But if the AO fails to unearth any wrong or illegal dealin .....

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r to find out causal connection between the cash deposited in the bank accounts of the applicant banks (sic companies) and the assessee were not taken. It is necessary to link the assessee with the source when that link is missing, it is difficult to fasten the assessee with such a liability. 39. We may repeat what is often said, that a delicate balance has to be maintained while walking on the tight rope of ss. 68 and 69 of the Act. On the on hand, one doubt, such kind of dubious practices are .....

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s herein) who invite the share application money from different sources or even public at large. It would be asking for a moon if such companies are asked to find out from each and every share applicant/subscriber to first satisfy the assessee companies about the source of their funds before investing. It is for this reason the balance is struck by catena of judgments in laying down that the Department is not remediless and is free to proceed to reopen the individual assessment of such alleged b .....

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ed or it is proved that it has "created" evidence, the Revenue is supposed to make thorough probe of the nature indicated above before it could nail the assessee and fasten the assessee with such a liability under ss. 68 and 69 of the Act. 2.5. If the ratio laid down in the aforesaid cases is kept in juxtaposition with the facts of the case, the Hon'ble High Court in the case of CIT vs Kamdhenu Steel and Alloys Ltd. & Ors. Vide order dated 23/12/2011 (2014) 361 ITR 220 (Del.) c .....

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ailed to carry his suspicion to logical conclusion by further investigation and therefore addition under section 68 was not sustainable. 2.6. While coming to aforesaid conclusion, the Hon'ble High Court duly considered the decision in Sarthak Securities Company Pvt. Ltd. vs Income Tax Officer (2010) 236 CTR (Del.) 362, CIT vs S.F.I.L Stock Broking Ltd. (2010) 233 CTR (Del.) 69 and Signature Hotels Pvt. Ltd. vs Income Tax Officer (2011) 60 DTR 30 (Del.). The following cases were also consider .....

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DTR (Del) 74: (2011) 333 ITR 119 (Del) vii. CIT vs. Orissa Corporation (P) Ltd. (1986) 52 CTR (SC) 138: (1986) 159 ITR 78 (SC) viii. CIT vs. Rajesh Jhaveri Stock Brokers (P) Ltd. (2007) 210 CTR (SC) 30: (2007) 291 ITR 500 (SC) ix. CIT vs. Rathi Finlease Ltd. (2008) 215 CTR (MP) 429 x. CIT vs. Sophia Finance Ltd. (1993) 113 CTR (Del)(FB) 472 : (1994) 205 ITR 98 (Del)(FB) xi. Sumati Dayal vs. CIT (1995) 125 CTR (SC) 124: (1995) 214 ITR 801 (SC) 2.7. If the aforesaid judicial pronouncements are an .....

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the same were served upon them. The ld. Assessing Officer if was still apprehensive nothing prevented him to take the legal recourse available with him. The assessee also filed confirmation from share subscribers. The bank accounts of share subscribers were produced which establishes their identity. The existence of share holders is not in doubt, their identity is established and they invested the money in purchase of shares. The onus cast upon the assessee has been established, therefore, foll .....

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