2026 (3) TMI 1281

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....r 2014-15 u/s. 143(3) of the Act. The Revenue has raised the following grounds:- 1. Whether on the facts and circumstances of the case, the ld. CIT(A) has erred in allowing relief to the assessee in deleting the addition of Rs. 6,35,58,000/- u/s. 68 of the Act being unexplained credits in the books of accounts of the assessee in the guise of share application money. 2. Whether on the facts and circumstances of the case, the CIT(A) has erred in allowing relief to the assessee by not examining the source of the investors of the assessee company which was cash deposits in bank account of third party and gift received from other relatives. 2. The brief facts of the case are that assessee filed return of income declaring an ....

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....e u/s. 131(1) to all the shareholders out of which 15 shareholders could not appear, as mentioned at page no. 4 of the assessment order. The shareholders who appeared before the AO got their statements recorded and those who could not appear had replied with documentary evidences. It is also submitted that none of the shareholders were in any relation to the assessee company be it employees or in any other capacity. It is further submitted that with respect to the issue of cash being deposited in the bank account of third party, as the issue has been raised by the department, it is submitted that in no case the shareholders have given money out of cash deposited in their bank accounts. However, there are few instances in which cash has been....

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....ese share holders were existing shareholders in the company. The AO issued notice u/s. 131(1) to all the shareholders out of which 15 shareholders could not appear, as mentioned at page no. 4 of the assessment order. The shareholders who appeared before the AO got their statements recorded and those who could not appear had replied with documentary evidences. With respect to the issue of cash being deposited in the bank account of third party, as the issue has been raised by the department, it is noticed that in no case the shareholders have given money out of cash deposited in their bank accounts. However, there are few instances in which cash has been deposited in the bank account of the persons from whom the shareholders have received th....