2022 (4) TMI 539

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....as taken the following grounds of appeal: "1. That on the facts and in the circumstances of the case, Ld. Commissioner of Income Tax (Appeals) was mistaken to limit the disallowance to the extent of Rs. 92,88,825/- on account of unverifiable creditors where the opening balance of the creditors for Rs. 34,08,875 brought forward from last year, was ignored which would not be income for the assessment year 2014-15. 2. That on the facts and in the circumstances of the case, Ld. Commissioner of Income Tax (Appeals) failed to construe that section 133(6) of Income Tax 1961 is not the only conclusive machinery to substantiate the veracity of transactions giving rise to creditors, where details of bank transaction with the said creditors were ....

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....ey have now supplied the copy of the ledger of the assessee in their books of accounts showing the aforesaid amount credited to the assessee. The ld. Counsel for the assessee has also relied upon the bank account statement to submit that the aforesaid amount was transferred to the assessee by the aforesaid creditors through banking channel. The ld. Counsel for the assessee has, therefore, submitted that the assessee may be given an opportunity to produce the aforesaid two creditors and relevant evidences to verify the genuineness of the transaction relating to the aforesaid credits and regarding the creditworthiness of the creditors. The ld. DR has relied upon the findings of the lower authorities to submit that the ld. CIT(A) had given ad....