TMI Blog2018 (4) TMI 343X X X X Extracts X X X X X X X X Extracts X X X X ..... The lower Appellate Authorities, after considering the submissions, clearly held that the record would indicate that the assessee had no privity of contract with the service provider. Having regard to the overall circumstances, the Court is of the opinion that no substantial question of law arises in this regard. Undisclosed income by way of bogus credits - Held that:- AO conducted a first leve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hrough: O R D E R The Revenue urges two question of law firstly, with respect to the disallowance under Section 40(A)(ia) of the Income Tax Act, 1961, and secondly, relating to the amounts of the alleged undisclosed income by way of bogus credits to the tune of ₹ 66,50,763/- claimed by the assessee. The assessee organisation entered into a contractual relationship with the Fede ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IH also included commission which was per se taxable, and therefore, tax deductable. The CIT(A) accepted the assessee s explanation that the reimbursement claimed was such as the assessee could not hold an independent inquiry into each transaction; the ITAT affirmed the decision. The Revenue urges that the facts clearly disclosed in the income, did exist in support of the transactions for which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s relating to the identity of the creditors, the AO did not further exert himself to obtain any information or documents from the concerned banks. In these circumstances, the lower Appellate Authorities correctly inferred that the assessee had discharged the initial burden of establishing the identity of the creditors, the genuineness of the transactions and the credit worthiness of the third part ..... X X X X Extracts X X X X X X X X Extracts X X X X
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