2018 (4) TMI 403

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..... as brought on record all the documents necessary to establish the creditworthiness of the creditors and genuineness of the transaction and the AO has not preferred to file any comment, we find no scope to interfere into the findings returned by ld. CIT(A). Moreover, perusal of the assessment order also goes to prove that the AO has not even preferred to summon the parties to make compete enquiry s .....

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..... transaction as well as their creditworthiness. In the assessee s appeal, the relevant details (PAN numbers, Tax Returns of creditors, copies of their bank account statements) were produced. The Appellate Commissioner sought a remand report. The AO did not respond to these documents though afforded an opportunity. Inferring that the AO had not displaced the onus that lay upon the Revenue, the CIT(A .....

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..... ildwell Pvt. Ltd.- ITA 928/2011 dated 15.11.2011 relied upon by ld. DR are not applicable to the facts and circumstances of the case. 18. In view of what has been discussed above, appeal being ITA no. 2222/De1./2014 filed by the Revenue is hereby dismissed. This Court considered the grounds of appeal; they urge pure questions of facts and appreciation of evidence. Having regard to the .....

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