ACIT v. Prasanna Purple Mobility Solutions P. Ltd. (2024)114 ITR 62(SN) (Pune)(Trib)

S. 68 : Cash credits-Share capital-Share premium-Loss making company-Genuineness of transaction is not proved-Addition is affirmed-Reassessment is affirmed. [S. 143(3) 147, 148]

Held that the reassessment is held to be valid. Tribunal also held that  that the  production of incorporation details, permanent account numbers, receipt of money through banking channel merely prove the identity and creditworthiness of the investors but not the genuineness of the transaction. The assessee has to discharge the onus cast upon it by demonstrating as to how the two parties were known to each other, the manner and mode by which the parties approached each other, whether the transaction was entered through written agreement as well as the creditworthiness, objects and purpose for which the investment was made. The fact that the assessee received huge share capital or share premium from a loss-making company,, triggered doubts about the genuineness of the very transaction. Further, the Assessing Officer’s allegation that it was the assessee’s unaccounted money had not been proved wrong. Addition is (AY.2011-12)

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