Tribunal partially allows appeal, stresses verifying new addresses, and upholding natural justice principles.

The Tribunal partly allowed the appeal for statistical purposes, emphasizing the importance of verifying the new addresses provided by the assessee and ensuring adherence to principles of natural justice in the proceedings.

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Issues:
Appeal against order deleting unexplained cash credit under section 68 of the Income Tax Act, 1961.

Analysis:
1. Background: The appeal was filed by the Revenue against the order passed by CIT(A) for the assessment year 2012-13, concerning the deletion of an addition of Rs. 1,98,50,000 on account of unexplained cash credit under section 68 of the Income Tax Act, 1961.

2. Assessing Officer's Observation: The Assessing Officer noted that the assessee company received share application money during the year, along with amounts from previous years, and un-allotted share application money. Subsequently, an addition of Rs. 1,98,50,000 was made as unexplained credit under section 68 of the Act.

3. Appeal Before CIT(A): The assessee filed an appeal before the CIT(A), who allowed the appeal, leading to the Revenue's challenge. The Revenue contended that the CIT(A) overlooked the genuineness and creditworthiness of the parties and accepted the assessee's contentions without proper verification.

4. Arguments: The Revenue argued that the CIT(A) failed to consider that the parties did not respond to the notices issued under section 133(6). In response, the assessee highlighted that all payments were made through banking channels, parties were tax-assessed in Delhi, and necessary documents were submitted to establish the genuineness of the credits.

5. Judicial Analysis: The Tribunal observed discrepancies in the addresses provided by the assessee and directed a fresh notice under section 133(6) to the share applicant parties for proper verification. The Tribunal emphasized the need for due process of law and remanded the matter back to the Assessing Officer for further adjudication.

6. Outcome: The Tribunal partly allowed the appeal for statistical purposes, emphasizing the importance of verifying the new addresses provided by the assessee and ensuring adherence to principles of natural justice in the proceedings.

This detailed analysis highlights the key arguments, observations, and the judicial decision made by the Tribunal in response to the appeal concerning the unexplained cash credit issue under section 68 of the Income Tax Act, 1961.

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