2014 (4) TMI 812

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....00/- made by the AO u/s 68 of the IT Act, 1961." 3. The other grounds raised by the Revenue are only arguments in support of above ground No.1. 4. The facts of the case are that during the accounting year relevant to assessment year under consideration, the assessee company had received share application money of Rs. 23,50,000/- from the following parties:- S.No. Name of share holder Amount 1. Sunita Gupta 3,00,000/- 2. Purnendu Kumar Gupta 3,00,000/- 3. Usha Rani 2,00,000/- 4. Jeetender Aggarwal 2,00,000/- 5. Deep Chand Gupta 2,50,000/- 6. Devi Ram Goyal 3,50,000/- 7. Amit Jain 2,50,000/- 8. Mukesh Jain 2,50,000/- 9. Vishal Agarwal 2,50,000/- ....

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....opy of bank statement. g) Source of fund from where she invested. 2. Purendu Kumar Gupta a) Confirmation for investment in shares. b) Income tax return copy for Ass. Year. c) Identity proof photocopy. d) PAN proof. e) Balance sheet of Mr. Purendu Kumar Gupta. f) Copy of bank statement. g) Source of fund from where he invested. 3. Jitender Aggrawal a) Confirmation for investment in shares. b) Income tax return copy for Ass. Year 2001-2002. c) Identity proof photocopy of his ration card. d) PAN proof. e) Balance sheet of Mr. Jitender Aggarwal. f) Copy of bank statement. g) Source of fund from where he invested. 4. Usha Rani a) Confirmation for investment in shares. b) Income tax return ....

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....irmation for investment in shares. b) Income tax return copy for Ass. Year. c) Identity proof photocopy. d) PAN proof. e) Balance sheet of Mr. Vishal Aggarwal. f) Copy of bank statement. g) Source of fund from where he invested." 7. From the above, it is evident that the assessee has given the confirmation in respect of all the creditors, copy of their income tax returns, identity proof, PAN proof, balance sheet, copy of bank statement as well as source of funds from where they invested in the share capital. The Assessing Officer did not accept the same because, in his opinion, the returned income, tax paid or the capital of the share applicants were not sufficient. In this regard, the Assessing Officer had prepared the....