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2019 (8) TMI 558

..... THAT:- The information received from the CBI only alleges that there was quid-pro-quo in receiving share capital. There should not be any doubt that it was only allegation at that point of time. Whether the said allegation could be the basis for forming belief that there was escapement of income is the moot question. In our view, the said allegation could trigger the investigation, but it alone cannot be the basis for arriving at the belief that there was escapement of income. AO should bring some other material to show that the apparent was not real or it does not satisfy the conditions of sec. 68. Nothing of that sort was brought on record by the AO while recording the reasons for reopening. Hence, we are of the view that the assessing officer was not right in law in reopening the assessment, as he could not have entertained the belief about escapement of income on the basis of reasons recorded by him. Information received from the CBI, as spelt out by the AO in the reasons recorded and in the remand report, would show that the CBI has alleged that the investments have been made by the applicants as quid pro quo to the benefits received by them. This information cannot be the bas .....

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..... to find out the veracity of the submissions made by the assessee. Under these set of facts, it has to be presumed that the AO was satisfied with the details furnished by the assessee. Hence, we are of the view that the decision rendered by Hon’ble Supreme Court in the case of NRA Iron and Steel P Ltd [2019 (3) TMI 323 - SUPREME COURT] shall not apply to the facts of the present case. - Decided in favour of assessee. - ITA No.698 And 699/Bang/2018, ITA Nos.700 And 701/Bang/2018 - 2-8-2019 - SHRI B.R BASKARAN, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER For The Appellant : Shri Percy Pardiwala, Sr. Advocate And Shri C.P Ramaswamy, Advocate For The Respondent : Shri K. V Arvind, Sr. Counsel for Dept. ORDER Per B. R Baskaran, Accountant Member All these appeals preferred by the respective assessees are directed against the orders passed by Ld CIT(A)-11, Bangalore and they relate to the assessment years mentioned in the cause title against the name of each of the assessees. All these appeals were heard together and hence they are being disposed of by this common order, for the sake of convenience. 2. These assessees have filed an Additional Ground in all the yea .....

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..... the original returns of income filed by these assessees for the years under consideration were accepted u/s 143(1) of the Act. In the reopened the assessment, the AO assessed the share application money and share premium received from these share applicants as income of the assessees herein. In respect of one subscriber of share named Shri Srinivasa Reddy, even the par value of shares was also assessed as income in AY 2008-09 in the case of Carmel Asia Holdigs P Ltd. The assessing officer was of the view that the method of allotment of shares was unusual, i. e. , It was seen that the share applicants have voluntarily applied for shares at huge share premium and the share premium so collected was not commensurate with the income earned by the assessees herein and also with their financial strength. Further there was no clarity on the basis of valuation of shares and determination of share premium. The assessee did not substantiate the quantum of share premium. The AO also noticed certain deficiencies in receipt of money, application forms, date of allotment of shares etc. Accordingly, the AO held that the transactions entered by these assessee on issue of shares are unusual and unre .....

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..... ssessee reiterated its contentions that the materials received from CBI were not confronted with the assessee. It was submitted that the AO has refused to furnish the materials by observing that the assessees may get the copies of those documents from the respective agencies. It was submitted that the assessee was not aware of the details of documents furnished to the assessing officer by CBI. 7. The Ld CIT(A), however, upheld the validity of reopening of assessment and his observations made in this regard are extracted below:- It is clear from the Reasons Recorded, reproduced above, that the AO has not relied upon the information about benefits received by various persons from the State Government of Andhra Pradesh to come to believe that income has escaped assessment. The AO on receipt of information has looked into the Returns filed by the appellant and noticed that it has received huge amounts of Share Premium which is not justifiable in the back ground of its actual activities and financial affairs and came to a belief that the amount received and labelled as Share Premium but income in the hands of the appellant which has escaped taxation. The AO is well justified in assuming .....

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..... capement of income. He submitted that the assessee has received share application money, share capital and share premium from reputed companies and the said fact is already available in the return of income filed by the assessee. No other material is available with the AO to form the belief that there was escapement of income except the information received from CBI. However, the Ld CIT(A) has taken the stand that the AO has not relied upon the said information. If that be the case, then the AO should have spelt out the details of other tangible materials, which led him to form the belief that the share application money/share premium constituted income in the hands of the assessee. Without tangible material, the AO could not have entertained belief about escapement of income and hence the reopening of assessment is not valid. In support of this proposition, the Ld A. R placed his reliance on the decision rendered by Hon ble Delhi High Court in the case of CIT vs. Orient Craft Ltd (354 ITR 536)(Delhi). The Ld A. R submitted that even if any material was available with the AO, it is mandatory to show that there was nexus between the said material and alleged escapement of income. Re .....

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..... of Smt. Sunita Dhadda, since there was violation of Principles of Natural Justice in not supplying the sworn statement given by a person, which was relied upon by the AO for making addition and also in not providing opportunity of cross examination to the assessee. The Ld A. R submitted that the decision so rendered by the Tribunal has since been upheld by the Hon ble Supreme Court. 13. The Ld A. R further submitted that the assessing officer has accepted the genuineness of share capital received by the assessee to the extent of its par value. He has disbelieved the quantum of share premium on the reasoning that the assessee companies are having lesser income and their financial strength does not justify the quantum of share premium. He submitted that the above said observation of the AO would not lead to the belief that there was escapement of income. He further submitted that the AO has also mentioned that the share applicant companies have benefitted from the State Government of Andhra Pradesh. The income, if any, arising out of such benefits would accrue to the share applicant companies only and not to the assessees herein. He submitted that the AO has also mentioned that the .....

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..... on. If the assessing officer has cause or justification to know or suppose that income had escaped assessment, it can be said to have reason to believe that an income has escaped assessment. The expression cannot be read to mean that the assessing officer should have finally ascertained the fact by legal evidence or conclusion. The function of the Assessing Officer is to administer the statute with solicitude for the public exchequer with an inbuilt idea of fairness to taxpayers. As observed by Delhi High Court in Central Provinces Manganese Ore Co Ltd v ITO (1991)(191 ITR 662), for initiation of action under section 147(a) (as the provision stood at the relevant time) fulfilment of the two requisite conditions in that regard is essential. At that stage, the final outcome of the proceeding is not relevant. In other words, at the initiation stage, what is required is reason to believe, but not the established fact of escapement of income. At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. Whether the materials would conclusively prove the escapement is not the concern at that st .....

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..... nt of amount raised by issuing shares at a premium u/s 68 of the Act in the case of NRA Iron & Steel P Ltd (412 ITR 161). It was held by Hon ble Apex Court that it is for the assessee to prove by cogent and credible evidence that the investments made in share capital are genuine borrowings, since facts are exclusively within the assessee s knowledge. The Hon ble Supreme Court has also observed that the practice of conversion of unaccounted money through the cloak of Share capital/premium must be subjected to careful scrutiny and this would be particularly so in the case of private placement of shares, where a higher onus is placed on the assessee since the information is within the personal knowledge of the assessee. It was further held that the assessee is under legal obligation to prove the receipt of share capital/premium to the satisfaction of the AO, failure of which, would justify addition of the said amount to the income of the assessee. The Ld D. R submitted that the assessees herein have collected hefty share premiums which were not commensurate with the financial strength and income of the assessees. Further the information received from CBI about quid pro quo has tri .....

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..... received any stake commensurate with the amount invested by them. So the assessing officer has the reason to believe that the amount invested by the companies is gratuitous in nature and since the same has not been offered for taxation the assessments were reopened. 20. The Ld A. R, accordingly, contended that the assessing officer has formed the belief only on the basis of information received from CBI, but the said information was not supplied to the assessee. The Ld A. R invited our attention to the following observations made by Hon ble Supreme Court in the case of Suraj Mall Mohta and Co. vs. A. V. Viswanadha Sastry (supra): - 19. When an assessment on escaped or evaded income is made under the provisions of S. 34 of the Indian Income tax Act, all the provisions for arriving at the assessment provided under S. 23(3) come into operation and the assessment has to be made on all relevant materials and on evidence and the assessee ordinarily has the fullest right to inspect the record and all documents and materials that are to be used against him. Under the provisions of section 37 of the Indian Income tax Act the proceedings before the Income tax Officer are judicial proceeding .....

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..... and also any other income chargeable to tax which has escaped assessment and which comes to his notice subsequently in the course of the proceedings under this section, or recompute the loss or the depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year) 23. It can be noticed that the assessing officer should have reason to believe that any income chargeable to tax has escaped assessment for any assessment year before he proceeds to invoke the provisions of sec. 147 for making assessment of escaped income. The assessing officer shall issue a notice u/s 148 of the Act, when he forms the belief that the income has escaped assessment and decides to reopen the assessment. As per section 148(2) of the Act, the assessing officer shall record his reasons for doing so before issuing any notice u/s 148 of the Act. In the instant cases, the assessing officer has recorded the reasons for reopening. For the sake of convenience, we extract below the reasons recorded by the assessee for reopening of assessment, as communicated to the assessees by the AO i .....

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..... ting to ₹ 4, 88, 763/- and total income of ₹ 2, 27, 230/-. The company has not shown income under any other head. The premium of ₹ 60, 59, 51, 640/collected from the investors mentioned in Table 1 above is not commensurate with the income reflected by M/s Carmel Asia Holdings. Pvt. Ltd, in its return of income. Further, the company has shown income only under the head "Interest Income" for A. Y. 2007-08. There is no reason for the companies listed in Table 1 above to pay such a huge premium amounting to ₹ 60, 59, 51, 640/- except for the fact that the company belongs to Sri Jagan Mohan Reddy Group of companies. It is reliably learnt on the basis of the investigations carried out by the CBI that the companies have received benefits from the State Government of Andhra Pradesh. It is clear that the company has not carried out any activity during the year. Therefore, there is no justification for allotting shares to the companies mentioned in Table-1 above, at a huge premium of ₹ 60, 59, 51, 640/- especially when the companies have not received any stake commensurate with the amount invested by them. I have reason to believe that the amount inves .....

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..... of M/s Carmel Asia Holdings P Ltd for AY 2007-08. 25. Before examining the above said reasons in the context of sec. 147 of the Act, we may discuss some of the decisions rendered by Hon ble Courts on the provisions of sec. 147 of the Act. The Hon ble Supreme Court has held in the case of Rajesh Jhaveri Stock Brokers P Ltd (supra) that, at the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. Hence it needs to be examined as to whether a reasonable person could have formed a requisite belief on the basis of material available with the assessing officer. 26. The meaning of the expression reason to believe has been explained by Hon ble Bombay High Court in the case of Hindustan Lever Ltd (supra) as under:- 21. …. . It is needless to mention that the reasons are required to be read as they were recorded by the Assessing Officer. No substitution or deletion is permissible. No additions can be made to those reasons. No inference can be allowed to be drawn based on reasons not recorded. It is for the Assessing Officer to disclose and open his mind through reasons recorded by him. He .....

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..... e to section 143(1) vis-à-vis section 147, the only ingredient is that there should be reason to believe that income chargeable to tax has escaped assessment . In the above said case, the return of income was processed u/s 143(1) of the Act, wherein the assessee had claimed deduction u/s 80HHC and sec. 10B of the Act. The assessee had declared duty drawbacks, DEPB, premium on DEPB and on sale of quota etc. in its profit and loss account. The AO reopened the assessment on forming opinion that the assessee was wrong in treating the proceeds of sale of quota as part of export turnover for claiming deduction u/s 80HHC of the Act. Accordingly, he formed the view that the assessee has been allowed deduction in excess and consequently income has escaped assessment. The Hon ble Delhi High Court, after discussing catena of decisions on reason to believe , held as under:- 18. In the present case, the reasons disclose that the assessing officer reached the belief that there was escapement of income on going through the return of income filed by the assessee after he accepted the return under section 143(1) without scrutiny, and nothing more. This is nothing but a review of the earlier .....

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..... even if the information is wholly vague, indefinite, far-fetched or remote. 29. We shall now examine the facts available in this case on the basis of legal principles explained by the Courts. It is the case of the revenue that the assessing officer has not formed his belief on the basis of information furnished by CBI. However, from the perusal of the reasons recorded by the assessing officer, it can be noticed that the assessing officer has referred to the search conducted by CBI in the initial paragraph and again refers to the investigations conducted by CBI in the last 4th paragraph. The information referred in the last 4th paragraph is extracted below, at the cost of repetition: - It is reliably learnt on the basis of the investigations carried out by the CBI that the companies have received benefits from the State Government of Andhra Pradesh. In the paragraph recorded below the table also, the assessing officer has mentioned that some of the companies namely, M/s Pioneer Infrastructure Holdings Ltd and M/s India Cements Ltd received benefits from the State Government of Andhra Pradesh. 30. We have noticed earlier that the Ld CIT(A) has called for a remand report from the AO a .....

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..... n reopened by issuing notice u/s 148 of the Act on 29-03-2014. It was contended by Ld D. R that the information received from CBI has only triggered the assessing officer to form belief that there was escapement of income, but he has not placed his reliance on those information for making impugned additions. However, the Ld A. R contended that the details relating to share capital/share premium collected by the assessee are already available in the return of income filed by the assessees. The details of alleged benefits received by the share applicants from Government of Andhra Pradesh are not available in the return of income. We have noticed that the AO has referred to the search conducted by CBI in the case of Sri Jagan Mohan Reddy and his Group companies in the reasons and further referred to the fact that the share applicant companies have received benefits from the State Government of Andhra Pradesh. In the remand report also, the assessing officer has referred to confidential facts, wherein he has stated that the CBI has alleged that the benefits were given to share subscriber companies for quid-pro-quo. Accordingly, we are of the view that the source of information about th .....

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..... re capital/share premium collected by the assessee in the reasons, the AO has also made following observations, i. e. , if the information received from CBI was not the basis for reopening, then the following observations would constitute the reasons for reopening. We have to examine as to whether these reasons would give rise to the belief that there was escapement of income. (a) the investor companies have not received any stake commensurate to their investments. Though the meaning of this sentence is not clear, yet the said observation shall not lead to the belief that there was escapement of income. (b) some of the companies namely M/s Pioneer Infrastructure Holdings Ltd and M/s India Cements Ltd received benefits from the State Government of Andhra Pradesh . This observation of the AO only gives information that these two investor companies have received benefits from State Government. The details of nature of benefits, how the investments made by them are related to it and how it would result in escapement of income in the hands of the assessee were not spelt out by the AO. This observation, in our view, does not lead to the belief that there was escapement of income. (c) The .....

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..... premium. It is well settled principle that the taxman is not entitled to sit in the arm chair of a businessman and regulate the business activities. Hence the question Whether there was justification for collecting huge share premium or not cannot be a ground for forming belief that there was escapement of income leading to reopening of assessment. (g) I have reason to believe that the amount invested by companies mentioned in Table 1 is gratuitous in nature. We notice that the meaning of the word gratuitous is given without receiving any return value . When a person makes investment in Shares of any company, he would get share certificate for the same and further the said share certificate is transferrable to other person for consideration. This is the mechanism prescribed under the Companies Act with respect to subscription of shares. Hence, it is not legally correct to categorise the share subscription as gratuitous in nature. Even, if it is considered as gratuitous payment, the AO has not shown as to how it can be considered as income in the hands of the assessees herein, as per the provisions of Income tax Act. 34. The above said analysis of the observations made by the asses .....

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..... time. Whether the said allegation could be the basis for forming belief that there was escapement of income is the moot question. In our view, the said allegation could trigger the investigation, but it alone cannot be the basis for arriving at the belief that there was escapement of income. The AO should bring some other material to show that the apparent was not real or it does not satisfy the conditions of sec. 68 of the Act. Nothing of that sort was brought on record by the AO while recording the reasons for reopening. Hence, we are of the view that the assessing officer was not right in law in reopening the assessment, as he could not have entertained the belief about escapement of income on the basis of reasons recorded by him. 38. We have noticed that the information received from the CBI, as spelt out by the AO in the reasons recorded and in the remand report, would show that the CBI has alleged that the investments have been made by the applicants as quid pro quo to the benefits received by them. This information cannot be the basis for reopening of assessment, since it is the assessing officer who has to apply his mind on the issue and take an independent view. It is not .....

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..... on u/s 68 is made on factual basis. The other decision relied on by Ld D. R is the decision rendered by Hon ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers P Ltd and the said decision lays down legal propositions on which there cannot be any quarrel. 40. In view of the foregoing discussions, we are of the view that the reopening of assessment is bad in law. Accordingly we allow the legal ground urged by the assessees and quash the orders passed by the tax authorities. 41. Since the parties have agreed that the above said decision can be applied on three other appeals under consideration, we hold that the reopening of assessment in the case of three other appeals is also bad in law and accordingly quash the orders passed by the tax authorities. 42. The Ld. Senior Advocate, Shri Percy Pardiwala advanced his arguments on merits of the additions. The case of Carmel Asia Holdings P Ltd for assessment year 2007-08 was taken up first. The Ld AR submitted that the AO has assessed the share application money and share premium only as income of the assessee in this year. He further submitted that the AO has not referred to any of the sections of the Income-tax Act for assessing .....

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..... he share application forms furnished by the share applicants. The AO has also referred to non-compliance of Articles of Association. The ld AR submitted that these deficiencies, at the most, may result in violation of provisions of Companies Act, in which case the transactions may be voidable at the instance of shareholders. The same would not lead to the conclusion that the share application and share premium received by the assessee are unexplained credits. 45. The ld AR submitted that the AO was not right in observing that there was no basis for charging such high premium. Inviting our attention to copy of valuation report placed in page 125 to 134 of the paper book, the ld AR submitted that the assessee has obtained a valuation report from a firm of Chartered Accountants, which would support the share premium collected by the assessee. The ld AR submitted that the above said valuation report was furnished to the AO along with the letter dated 26-03-2015. Accordingly he submitted that there was no scope for making any addition u/s 68 of the Act on the ground of high share premium. 46. The ld AR invited our attention to the letter dated 25. 2. 2015 placed at page No. 50-53 of the .....

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..... He submitted that all these companies have duly disclosed the investment made by them in the assessee companies. 49. The Ld A. R submitted that the decision rendered by Hon ble Supreme Court in the case of NRA Iron & Steel (P) Ltd (supra) will not apply to the facts of the present case. Inviting our attention to the decision rendered by Hon ble Supreme Court in the above said case, the Ld A. R submitted that the assessee therein was called upon by the AO to furnish details of the amount received and provide evidence to establish identity of the investor companies, credit worthiness of the creditors and genuineness of transactions. The Assessee furnished copies of income tax returns of the investor companies and submitted that the money was received from banking channels. Accordingly the assessee contended that the onus placed upon it u/s 68 of the Act stands discharged. Thereafter, the AO issued summons to investor companies. Nobody appeared before the AO, but replies were received by post. Hence the AO got field enquiries conducted independently and the result of enquiry was summarised by the AO in the assessment order, which showed that many companies did not exist at the giv .....

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..... case of Carmel Asia Holdings P Ltd in AY 2008-09 and Janani Infrastructure P Ltd in AY 2007-08 and 2008-09, subject to following modifications:- (a) In the case of Carmel Asia Holdings P Ltd, the AO has added share capital amount also in AY 2008-09 in respect of amount received from Shri Srinivasa Naidu. (b) In the case of Janani Infrastructure P Ltd, the said assessee has received share capital in AY 2008-09 from Carmel Asia Holdings P Ltd to the tune of ₹ 273. 21 lakhs. The AO has assessed the same on protective basis. The Ld A. R submitted that the arguments made by him shall apply to the above said appeals also. 53. The Ld D. R, on the contrary, submitted that the assessing officer has called the assessee to substantiate the genuineness of share premium collected by the assessee. However, the assessee has failed to substantiate the same. The Ld D. R submitted that the Hon ble Supreme Court has held in the case of NRA Iron & Steel P Ltd (supra) that the assessee is required to prove the genuineness of the transactions relating to collection of share premium. He submitted that the Hon ble Supreme Court has sustained the addition of Share premium in the above said case, .....

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..... ue and allotment of shares are within the four corners of law. The AO/CIT(A) has not brought on record any issues with the issue and allotment of shares since they are issued and allotted as per the Companies Act and rules that existed at the time of issue and allotment of shares. The determination of share premium may not be as per industries norm or investor norms but these were fixed and accepted by the investing parties. 9. 1 ……. The arrangement and circumstances leading to issue and allotment of shares may draw some doubts that certain benefits may have passed on to the directors. But the question is whether the directors/shareholders have really benefitted with this arrangement and the assessee company was used as arrangement to pass on the benefit. The revenue has to prove that the investors have passed on the benefit to the shareholders/directors through this arrangement by bringing cogent material. But the AO/CIT(A) has brought on record so many incidences and alleged benefits which were enjoyed by the investors from the Govt. of AP. But, what is important is that the funds were invested in the company and the company has demonstrated that it has treated the .....

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..... , the additions made by the assessing officer in the hands of both the assessees in the years under consideration are liable to be deleted. 61. We noticed that the Ld CIT(A) has applied the theory of Human Probabilities. We also noticed that the Hyderabad bench of Tribunal has observed in the case of Bharati Cement Corporation (supra) that the test of human probabilities cannot be applied to business transactions, as they are based on cogent materials. In any case, the Ld D. R has agreed that the receipt of share premium has to be tested u/s 68 of the Act. Hence the theory of human probabilities cannot be applied in this case. 62. We have noticed that the Ld D. R has clarified that the additions have been made u/s 68 of the Act. From the assessment order as well as from the paper book furnished by the assessee, it can be noticed that the assessee has furnished all the details that were called for by the AO. We notice that the AO has treated the share premium has unexplained cash credit only for the reason that the same was commensurate with the size of the income and financial strength of the assessee. We have noticed that the AO has reached to this conclusion without carrying out .....

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..... ed that the revenue has given a finding that the there has been routing of money for illegal purposes through a chain of companies in which the assessee is a conduit in the layering process. The AO has carried out investigations and has given several adverse findings. Under those set of facts, the co-ordinate bench has held that the assessee has failed to prove the genuineness of the share premium and accordingly confirmed the addition. In our view, the facts of the present case are different and hence the revenue cannot take support of the above said decision rendered by the Tribunal. 67. In the instant case, as noticed earlier, it is not the case of the assessing officer that the assessee did not furnish any of the details called for by him. Further, the assessing officer did not find any fault with the documents furnished by the assessee except some deficiencies in the application forms filed by the assessee, which are procedural mistakes. The AO also did not make any independent enquiry with the share applicants in order to find out the veracity of the submissions made by the assessee. Under these set of facts, it has to be presumed that the AO was satisfied with the details fu .....

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