High Court affirms CIT(A) & ITAT on identity, creditworthiness, genuineness. No substantial question of law. Appeal dismissed.

The High Court upheld the findings of the CIT(A) and ITAT regarding the identity, creditworthiness, and genuineness of the transactions as factual, concluding that no substantial question of law arose. The appeal against the ITAT order deleting the addition under Section 68 of the Income Tax Act for the assessment year 2006-07 was dismissed.

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Issues:
Appeal against ITAT order deleting addition under Section 68 of the Income Tax Act for assessment year 2006-07.

Analysis:
1. The appeal was filed against the ITAT order dismissing the Revenue's appeal against the CIT(A) order deleting the addition of Rs. 1,81,46,869 made by the AO under Section 68 of the Income Tax Act for the assessment year 2006-07.
2. The assessee, engaged in business, declared total income of Rs. 32,93,790 for the assessment year 2006-07. The AO found cash credits in the books during 2005-06 as bogus advances and added them back under Section 68. The CIT(A) found 13 creditors' advances genuine, restricting the addition to Rs. 13,39,750. The ITAT dismissed the Revenue's appeal against the CIT(A)'s order.
3. The appellant contended that the ITAT erred in not discussing the grounds disproving the creditors' creditworthiness. The appellant argued that while identity was proven, creditworthiness and genuineness were not. The ITAT confirmed the CIT(A)'s order based on the creditors' acceptance of advancing credits and providing deposit sources.
4. The CIT(A) discussed each transaction's creditworthiness and genuineness, finding 13 creditors genuine. The ITAT held that the assessee met the required creditworthiness proof. The ITAT opined that the assessee shouldn't prove 'source of source,' and stretching Section 68's requirements too far would not render the cash credits ingenuine.
5. The High Court upheld the findings of the CIT(A) and ITAT regarding the identity, creditworthiness, and genuineness of the transactions as factual, concluding that no substantial question of law arose. The appeal was dismissed.

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