Renu Proptech Pvt Ltd. Vs ACIT (ITAT Delhi)
Considering the plethora of documentary evidences, we find that not only the assessee has established the source of the creditor, but it has also furnished documentary evidences to show the’ source of source’. We find that the AO, while making addition, has made general observations relating to the circulation from one source to the other.
On the one hand, the AO observes that all the share applicants/individuals/HUF/companies are related to the assessee company and on the other hand the AO is doubting the identity of the share applicants. The AO cannot blow hot and cold in the same breath. Further, the first appellate authority, while deleting the additions on account of 10 share applicants on the same set of facts has erred in confirming the addition on account of two share applicants, namely, Shri Anand Gupta, HUF and Shri Sanchit Gupta.
Team – Intellex Strategic Consulting Pvt Ltd
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