TaxTMI 
TaxTMI 
2021 (2) TMI 653
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....ner erred in confirming an amount of Rs. 1,80,00,000/- as unexplained cash credits u/s. 68 of the Income Tax Act, as added by the A.O. 3. The Appellate Commissioner erred in confirming an amount of Rs. 34,59,182/- as unexplained investments u/s. 69 of the Income Tax Act, as added by the A.O. 4. The Appellate Commissioner erred in confirming an amount of Rs. 17,640/- being depreciation claimed by the assessee and disallowed by the A.O. 5. The Appellate Commissioner erred in confirming an amount of Rs. 24,000/- being disallowance u/s. 80GG as disallowed by the A.O. 6. The Appellate Commissioner erred in confirming an amount of Rs. 4,16,129/- being expenses claimed by the assessee and disallowed by the A.O. ....
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.... loans amounting to Rs. 1.80 crores from three parties, viz., M/s. Candid Wealth Management Pvt. Ltd., New Delhi, - Rs. 90 lakhs, from M/s. Safari Tradex Pvt. Ltd., New Delhi, - Rs. 30 lakhs, and from M/s. Wizard Realcon Pvt. Ltd., New Delhi - Rs. 60 lakhs. When the assessee was asked to furnish confirmations of the loan creditors along with their income-tax particulars, the assessee filed ledger extracts of the loan creditors with their signature obtained form them on the extracts and also filed name, address and PAN of the parties. On verification of the ledger extracts, the AO found that the assessee had not paid any interest on the said borrowings of Rs. 1.80 crores. In order to verify the identity of the creditors, capacity of the cred....
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.... identity of the loan creditors, genuineness of the loan transactions and credit worthiness of the loan creditors, the lower authorities were not appreciated the same and doubted the transactions and made the addition. He, therefore, pleaded that the issue may be remitted back to the file of the AO for reverification of the documents filed by the assessee and decide the issue in accordance with law. 7.2. The ld. DR has no objection to remit the matter back to the file of the AO. 7.3. After hearing both the parties and perusing the material on record as well as going through the orders of the authorities below and after taking into consideration the submission of the ld. counsel for the assessee, we are inclined to remit this issue bac....
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....f the assessee. 8.1. The CIT(A) confirmed the addition by holding that no documentary evidence was furnished even before him to prove the source of capital introduced. 8.2. The Ld. counsel for the assessee reiterated the submissions as made in ground No. 2 that the lower authorities failed to consider the explanation offered by the assessee and, he requested to remit the issue back to the file of the AO to redecide the same, for which, the ld. DR has no objection. 8.3. After considering the submissions of both the parties and perusing the material on record as well as the orders of the authorities below, we remit this issue also back to the file of the AO with a direction to redecide the issue after taking into consideration the su....