2006 (4) TMI 93

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....as share application money. The Assessing Officer added the said amount to the taxable income of the assessee under section 68 of the Income-tax Act, 1961, on the ground that the identity of the subscribers had not been established. In an appeal filed by the assessee against the said order, the Commissioner of Income-tax (Appeals) held that the assessee had satisfactorily established the identity ....

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....of Income-tax (Appeals) has considered the facts and circumstances in detail and has recorded findings of fact. He has also placed reliance on the decision in the case of CIT v. Sophia Finance Ltd. [1994] 205 ITR 98 (Delhi) [FB]. The learned Commissioner of Income-tax (Appeals) has also considered the provisions of sections 72, 75 and 77 of the Companies Act and has also taken into consideration t....