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TMI Blog2021 (7) TMI 895X X X X Extracts X X X X X X X X Extracts X X X X ..... ny only which had escaped the consideration of learned lower authorities. We therefore restore the instant sole issue back to the AO for his fresh adjudication as per law. The assessee or its authorised representative shall appear before the AO on or before 30-11-2021 and shall file all the necessary details of investor entity at its own risk and responsibility to be followed by three effective ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ating its share application money of ₹ 3,79,00,000/- as un-explained cash credits u/s. 68 of the Act. The CIT(A)'s detailed discussion to this effect reads as under: 5. All the grounds of appeal are against the addition of ₹ 3,79,00,000/- U/s. 68 of the I.T. Act. The AO treated an amount of ₹ 3.79 crores as unexplained for want of documentary proof for the claim of genui ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons were cited for non-submission of details before AO. It was stated by AR of the appellant that the money received towards share application was not utilized towards issue of shares. It was further stated by the AR of the appellant that the money received is pending for allotment of shares even today. The money was also not re-paid to the so called subscriber of the share even after considerable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entity was in fact its group entity having common director(s) and the same address as well. The same has nowhere been considered either in the course of assessment or in the CIT(A)'s order. The fact also remains that the assessee has not proved genuineness/creditworthiness of its group concern by filing all the necessary details. 4. Faced with this situation, learned authorised representat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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