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TMI Blog2016 (6) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... ands dismissed by the ITAT - HELD THAT:- CIT(A) discussed the creditworthiness and genuineness of each and every individual transaction and found 13 creditors as genuine - ITAT has arrived at the finding that the assessee has established the creditworthiness of the creditors to the extent he is obliged under the law to do so. ITAT found that the creditors have accepted that they had advanced th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal is directed against order dated 30.8.13 of Income Tax Appellate Tribunal (ITAT), Jodhpur Bench, Jodhpur, whereby an appeal preferred by the Revenue against the order of Commissioner of Income Tax (Appeals) [CIT(A)], Udaipur, dated 30.11.12, deleting the addition of ₹ 1,81,46,869/- made by the Assessing Officer (AO) under Section 68 of the Income Tax Act, 1961 ( for short the Act ), v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red loans were acquired during the previous year relevant to the assessment year 2006-07. In response to the notice, the assessee furnished copy of the account of the parties as appearing in the books of accounts giving the details of credit obtained from the creditors. After due consideration of the evidences gathered, the AO arrived at the finding that the cash credits appearing in books of asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y the ITAT. Hence, this appeal. 3. Learned counsel for the appellant contended that ITAT has seriously erred in not discussing the various grounds of the appeal of the Revenue wherein the specific short comings disproving the credit worthiness of the creditors are highlighted. Learned counsel submitted that AO had arrived at a categorical finding that credits do not fulfil three parameters of S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... creditors have accepted that they had advanced their respective credits to the assessee and also given the details of the sources of the deposit. The ITAT opined that the assessee cannot be burdened with proof of 'source of source' and the cash credit cannot be held to be ingenuine by stretching the ingredients of Section 68 too far. We are of the considered opinion that the findings arri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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