TMI Blog2022 (4) TMI 278X X X X Extracts X X X X X X X X Extracts X X X X ..... iness of the concerned persons. In support of its contention, the assessee/persons have not filed all the relevant details before the lower authorities, meaning thereby, the assessee has not discharged his onus. In our considered opinion, the abovesaid details do not prove the creditworthiness of the persons those have paid premium. So, in view of the above, we set aside this matter back to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt order dated 17.03.2015 passed by the Assessing Officer (AO) under s. 143(3) of the Income Tax Act, 1961 (the Act) concerning AY. 2012-13. 2. The grounds of appeal raised by Revenue read as under: 1. The Ld. CIT(A) erred in law and on facts in deleting the addition of ₹ 2,92,00,000/- made by the Assessing Officer u/s. 68 of the Income Tax Act, 1961. 2. The Ld. CIT(A) erred in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dentity of the persons, genuineness of transaction and creditworthiness as per section 68 of the Act. In response to the notices u/s. 133(6) to the concerned persons they have filed copy of income tax return. On perusal of income tax return, it was found that these people are not creditworthy to invest such large amount in a Pvt. Ltd. Company. Therefore, the assessee was again asked to establish t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,27,000/-. Before the lowers authorities, assessee has filed copy of the income tax return, PAN numbers of the concerned persons and also filed bank statements. But learned AO doubted the creditworthiness of the concerned persons. In support of its contention, the assessee/persons have not filed all the relevant details before the lower authorities, meaning thereby, the assessee has not discharge ..... X X X X Extracts X X X X X X X X Extracts X X X X
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