9911796707
TMI Blog2024 (6) TMI 1300X X X X Extracts X X X X X X X X Extracts X X X X ..... ge amount came into the possession of the assessee in the form of cash - CIT(Appeals) deleted such additions on the grounds that confirmations were signed by authorised signatory, as person who advanced loan was in custody at the time of assessment proceedings and such loan from directors and promoters of the group with their PAN number, details of assessment etc. were with AO himself and such loa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellant Revenue has proposed the following questions arising from order dated 19.05.2023 passed by the Income Tax Appellate Tribunal, D Bench, Ahmedabad (For short the Tribunal ) in ITA No. 1917/Ahd/2014 for AY 2008-2009: (A) Whether on the facts and circumstances of the case and in law, the order of the Appellate Tribunal is ex facie perverse because the Appellate Tribunal has deleted the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f cash. 4. However, CIT(Appeals) considering the audited cash book as well as reconciliation statement placed on record by the assessee showing withdrawal from the bank account came to the conclusion that the Assessing Officer cannot reject such explanation on the presumption that appellant cannot have such cash on hand in the business of import export of agricultural commodity. CIT(Appeals) there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee were not filed under the hand and signature of the person from whom the loan had been taken, it was presumed that the assessee failed to prove the creditworthiness of such parties. 8. CIT(Appeals) however deleted such additions on the grounds that confirmations were signed by authorised signatory, as person who advanced loan was in custody at the time of assessment proceedings and such lo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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