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TMI Blog2022 (8) TMI 1081X X X X Extracts X X X X X X X X Extracts X X X X ..... s enclosed. Share applicants filed their income tax return and furnished P L A/c, computation of income etc. It is seen that the assessee has also filed part of the bank statement. However, it is seen that the balance sheet and computation of P L A/c filed by the assessee is not commensurate with the investment made by the share applicants. It is also seen that the assessee has not filed the entire balance sheet of the share applicants for the AY 2012-13 - Appeal of the assessee is dismissed. - ITA No. 2094/Del/2019 - - - Dated:- 24-8-2022 - SHRI KUL BHARAT , JUDICIAL MEMBER Appellant by : None Respondent by : Shri Om Parkash, Sr.DR ORDER PER KUL BHARAT , JM : The present appeal filed by the assessee for the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r section 147/143(3) of the Act, confirming the addition made by the AO on account unsecured loan of Rs. 10,00,000/- as alleged unexplained cash credit treating the same as undisclosed income under section 68 of the Act. 4. The appellant craves leave to add, alter, modify or delete one or more ground of appeal before or at the time of hearing of appeal. 3. At the time of hearing, no one attended the proceedings on behalf of the assessee. It is seen from the records that the hearing of the appeal has been adjourned many times and since 04.02.2021, there was no representation on behalf of the assessee. Notices of hearing were duly sent by the Registry and the notices sent were returned back unserved with remark left by the Posta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... peal before Ld.CIT(A), who after considering the submissions, dismissed the appeal of the assessee and sustained the addition made by the AO. 7. Aggrieved against the order of Ld.CIT(A), the assessee is in appeal before this Tribunal. 8. The assessee through grounds of appeal and the statement of facts filed alongwith appeal memo has assailed the action of the authorities below. It is stated that the original assessment of the assessee was completed u/s 143(3) of the Act on 28.01.2015 at income of Rs.40,890/-. It is further stated that the case was re-opened on the basis of the information received from Investigation Wing of the Department wherein a search and Seizure operation was carried out on Shri Deepak Agarwal and Shri Mukesh Ku ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubmitted by the assessee. He strongly relied upon the orders of the authorities below and submitted that it was incumbent upon the assessee to prove the genuineness of the transaction, identity of the share applicants and creditworthiness of such share applicants. The assessee failed to discharge primary onus to prove these three conditions. Therefore, there is no infirmity into the orders of the authorities below. 10. I have heard the contention of Ld. Sr. DR and perused the material available on record and gone through the orders of the authorities below. The AO made addition on the basis that during the year under consideration, the assessee had received certain share application money from share applicants namely M/s. I Tech Insuranc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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