TMI Blog2023 (7) TMI 393X X X X Extracts X X X X X X X X Extracts X X X X ..... no additions needed to be made in appellant's present case No material/evidence was ever produced by the Appellant, neither is available on record to substantiate the grounds raised in this appeal by the Appellant and to controvert the findings of the ld. Authorities below to the effects that the Appellant failed to discharge its onus to establish the identity and creditworthiness of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dated 05.02.2019, impugned herein, passed by the learned Commissioner of Income-tax (Appeals)-8, New Delhi (in short Ld. Commissioner ), u/s. 250 of the Income-tax Act, 1961 (in short the Act ) for the assessment year 2010-11. 2. From the record it reveals that several notices fixing for the dates of hearing including on 20.03.2023, were issued to the Appellant at the address given in Form-3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ructure Pvt. Ltd.) controlled by Shri Pradeep Kumar Jindal, however failed to discharge its onus of providing the identity and creditworthiness of such party. The Assessing Officer therefore made the additions of Rs. 1,27,00,000/- and Rs. 2,54,000/- respectively u/s. 68 of the Act and on account as commission on the above amount of accommodation entry. 4. The Appellant challenged the said addit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at this is a case of accommodation entry. On merits also, during appellate proceedings, no further details have been filed by appellant company, despite allowing opportunity of being heard in that regard, so as to justify its claim that no additions needed to be made in appellant's present case. Therefore on those facts, I have no reason to interfere with the findings of the AO and provide any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsaction. Therefore, the onus cast upon the Appellant to fulfil the conditions of section 69 of the Act, does not stand discharged. Consequently, the findings recoded by the ld. Commissioner in the impugned order, does not call for any interference. Accordingly, the impugned order is liable to be affirmed. 6. In the result, the appeal filed by the Appellant stands dismissed. Order pronounc ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
