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ITAT held that the Pr.CIT's revision u/s 263 and consequential addition u/s 68 for unexplained cash credits were unsustainable. The assessee had furnished complete evidences establishing identity, genuineness and creditworthiness of share subscribers, including responses to notices u/s 133(6) and compliance with summons u/s 131, with payments made through banking channels. Mere non-traceability of some subscribers at later dates could not justify addition u/s 68 in absence of contrary material. ITAT further held that reassessment proceedings initiated u/s 147/148 were barred by limitation, as the original assessment u/s 143(3) had examined and accepted the disclosed transactions and losses, leaving no failure to fully and truly disclose material facts. The reassessment was quashed and the assessee's appeal allowed.
ITAT held that the Pr.CIT's revision u/s 263 and consequential addition u/s 68 for unexplained cash credits were unsustainable. The assessee had furnished complete evidences establishing identity, genuineness and creditworthiness of share subscribers, including responses to notices u/s 133(6) and compliance with summons u/s 131, with payments made through banking channels. Mere non-traceability of some subscribers at later dates could not justify addition u/s 68 in absence of contrary material. ITAT further held that reassessment proceedings initiated u/s 147/148 were barred by limitation, as the original assessment u/s 143(3) had examined and accepted the disclosed transactions and losses, leaving no failure to fully and truly disclose material facts. The reassessment was quashed and the assessee's appeal allowed.
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