PCIT v. Esspal International (P.) Ltd.(2025) 473 ITR 329 (Raj) (HC)

S. 68 : Cash credits-Share application-Accommodation entries-Identity, creditworthiness and genuineness of transactions are established-Order of Tribunal deleting the addition is affirmed-Statement is retracted-Order of Tribunal is affirmed [S. 132(4), 260A]

Dismissing the appeal of the Revenue the Court held that Tribunal had noted that assessee had furnished each and every document required for proving identity, creditworthiness of share applicants and genuineness of transactions, however, Assessing Officer had not been able to brought on record any evidence to show that cash was paid by assessee to any person for obtaining accommodation entries in form of share application money. Court also held that  as matter of record that SCS had retracted his statements given before Assessing Officer. On facts  addition made by Assessing Officer was without any basis. Followed Pullangode Rubber Produce Co Ltd v. State of Kerala (1973) 91 ITR 18 (SC) (AY. 2011-12)

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