2019 (10) TMI 1209

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.... Rs. 2,94,500/- as unexplained credit for the year in the case of M/s. J. J. Metals. II. Addition of Rs. 3,00,000/- as unexplained credit for the year in the case of M/s. Poonam Realtors. A. Adjudication of the ground-addition of Rs. 2,94,500/- as unexplained credit for the year in the case of M/s. J. J. Metals. 3. The facts with regard to the issue is that the assessee is a Private Limited Company and filed its return of income for the assessment year under consideration on 31.11.1998 declaring total income of Rs. 5,86,730/-. With regard to the M/s. J.J. Metals, the Assessing Officer observed that the assessee has shown credit balance of Rs. 14,67,300/-. As the credit is not proved by the assessee, Assessing Officer added to the incom....

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....tment. The Ld. AR further submitted that all the transactions were done through banking channels only and payments were received via account payee cheques and accordingly, the Ld. AR prayed that addition of Rs. 2,94,500/- may be deleted. 7. The Ld. DR relied on the order of the sub-Ordinate Authorities and submitted that addition made on account of unexplained credit may be sustained. 8. We have perused the case records and heard the rival contentions. We find that out of the total addition of Rs. 14,67,300/-, an amount of Rs. 11,72,800/- has already been explained by the assessee. There is dispute only to the extent of Rs. 2,94,500/-. We further observe that substantial amount has been explained by the assessee in the given situation and....

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.... for the entire Rs. 6,00,000/-. As per Para 11.2 of the order of Ld. CIT(Appeals), it is evident that the assessee has submitted various documents before the Assessing Officer as evidence to prove the source and genuineness of the transactions. However, those documents were not considered by the Assessing Officer while finalizing assessment. The Ld. CIT(Appeals) observed that regarding M/s. Poonam Realtors, a proprietary concern, the assessee failed to submit even the confirmation letter and even PAN was also not given and therefore, the genuineness of the transactions remained unproved and accordingly, an amount Rs. 3,00,000/- was confirmed by the ld. CIT(Appeals). 11. At the time of hearing through e-court, the Ld. AR of the assessee su....