Held that the assessee failed to produce or provide the complete addresses of the two alleged shareholders nor submit any evidence to show the source of funds in their hands ; during the course of assessment the assessee did not seek cross-examination of the alleged shareholders. The grounds raised by the Department for the year under consideration were identical to those raised in the assessment year 2013-14 except for the quantum of the amount. It was evident that in the preceding year the assessee had admitted the addition made by the Assessing Officer on identical grounds ; in view of the rule of consistency, the assessee was not justified in raising the dispute without any valid reason. The findings of the Commissioner (Appeals) was upheld. (AY.2014-15)
Mahamedha Urban Co-Operative Bank Ltd. v. Dy. CIT (2022) 99 ITR 669 (Delhi) (Trib)
S. 68 : Cash credits-Share application money-Failure by share applicants to appear for inquiry in response to summons-Summons not served on some others-Addition is affirmed [S. 131]