D.C.I.T.,CIRCLE-1(4), KOLKATA vs. EDMOND FINVEST PVT. LTD., KOLKATA

आयकर अपीलीय अधिकरण कोलकाता 'बी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH, KOLKATA श्री संजय गगग, न्याधयक सदस्य एवं डॉ. मनीष बोरड, लेखा सदस्य के समक्ष Before SRI SANJAY GARG, JUDICIAL MEMBER & DR. MANISH BORAD, ACCOUNTANT MEMBER I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 DCIT, CC-1(4), Kolkata.............................................Appellant Vs. M/s. Edmond Finvest Pvt. Ltd....….........................Respondent (Earlier known as Edmond Textiles Pvt. Ltd.) [PAN: AAACE 6908 L] Appearances by: Sh. P.P. Barman, Addl. CIT, appeared on behalf of the Revenue. Sh. Akkal Dudhwewala, A/R, appeared on behalf of the Assessee. Date of concluding the hearing : February 16th, 2023 Date of pronouncing the order : May, 16th, 2023 ORDER Per Manish Borad, Accountant Member: This appeal filed by the Revenue pertaining to the Assessment Year (in short “AY”) 2015-16 is directed against the order passed u/s 250 of the Income Tax Act, 1961 (in short the “Act”) by ld. Commissioner of Income Tax (Appeal)-24, Kolkata [in

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) short “ld. CIT(A)”] dated 28.11.2019 arising out of the Assessment Order framed u/s 143(3) of the Act dated 15.12.2017. 2. Registry has informed that the appeal filed by the Revenue is time barred by 306 days. The Revenue vide application dated 05.03.2021 stated that the delay was on account of COVID-19 restrictions. We, therefore, in view of the judgment of The Hon’ble Supreme Court vide Miscellaneous Application No. 21 of 2022 find that the limitation period in filing appeal between 15.03.2020 till 28.02.2022 has been excluded for calculating the limitation period. Since the period of limitation in the case of the Revenue falls during this period, the same deserves to be extended and we, therefore, condone the delay and admit the appeal for adjudication. 3. The Revenue is in appeal before this Tribunal raising the following grounds: “1) Whether on facts of the case and in law, Ld. CIT(A) has erred in allowing assessee’s appeal in respect of addition of unsecured loans made u/s 68 of the Act along with disallowance of corresponding interest expenses, without appreciating full facts available on record? 2) Whether on facts of the case and in law, Ld. CIT(A) has erred in deleting addition of Rs. 1,00,00,000/- made by AO u/s 68 along with disallowance of interest expenses thereon of Rs.1,94,958/-, by merely relying on the form rather than the substance of impugned unsecured loan transactions? 3) Whether on facts of the case and in law, CIT(A) has erred in allowing assessee’s appeal on addition made in respect of unsecured loans from three parties along with disallowance of corresponding interest, without taking due cognizance of the ratio laid down by Hon’ble Apex Court decisions in cases of Pr. CIT(Central), Delhi vs. NRA Iron & Steel P Ltd 412ITR 161 and CIT vs. P. Mohankala 291ITR 278? Page 2 of 26

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) 4) Whether on facts of the case and in law, CIT(A) has erred in allowing assessee’s appeal on the issue of disallowance of Rs. 3.29 cr. made under Section 14A r.w.r.8D, without considering that AO had duly recorded his satisfaction before invoking provisions of section 14A and Rule 8D? 5) Whether on facts of the case and in law, CIT(A) has erred in allowing assessee’s appeal cm the issue of disallowance made by AO under Section I4A r.w.r. 8D, without appreciating the fact that disallowance was made following principle emanating from CBDT Circular S/2014. 6) That department craves leave to add, alter or modify any or all grounds of appeal either before or during course of Appellate proceedings.” 4. Brief facts of the case as culled out from the records are that the assessee is a private limited company and is a Non-Banking Finance Company (in short ‘NBFC’). Loss of Rs. 63,52,023/- declared in the return filed for AY 2015-16 dated 29.09.2015 which was subsequently revised on 31.03.2017 disclosing loss of Rs. 3,92,79,740/-. Case selected for scrutiny through CASS followed by serving of notices u/s 143(2) & 142(1) of the Act. Ld. AO while carrying out the assessment proceedings, specifically asked the assessee to explain the source of unsecured loan of Rs. 1 Cr taken from three companies. The assessee filed various details including balance sheet, bank statement and other relevant details. Ld. AO, further, issued the notice u/s 131 of the Act but they were not complied and the directors of the alleged creditors did not appear. For this reason, ld. AO came to a conclusion that the assessee failed to discharge its onus to explain the source of the unsecured loan of Rs. 1 Cr and made the addition u/s 68 of the Act. Along with other additions/disallowances, total loss assessed at Rs. 55,86,642/- and a separate addition for unexplained cash credit Page 3 of 26

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) made under the head ‘Income from other sources’ at Rs. 1 Cr computed u/s 115BBE of the Act. Book loss computed at Rs. 1,38,38,297/- after adding back the disallowances u/s 14A of the Act at Rs. 3,29,27,717/-. 5. Aggrieved, the assessee preferred appeal before ld. CIT(A) and partly succeeded. 6. Aggrieved, the Revenue is now in appeal before this Tribunal. Ld. D/R vehemently argued supporting the order of ld. AO and further added that the assessee failed to explain the source of unexplained cash credit since the alleged creditors did not appear before ld. AO to explain the genuineness of the transaction. 7. On the other hand, ld. Counsel for the assessee vehemently argued relying on the detailed finding of ld. CIT(A) and further referred to the paperbook containing 116 pages which includes the audited financial statement, computation of income, extract of bank statement evidencing the receipt and repayment of inter- corporate loans through proper banking channel and financial statement of the alleged creditors. 8. We have heard rival contentions and perused the records placed before us. First issue for our consideration raised by the Revenue in ground nos. 1, 2 & 3 relates to addition u/s 68 of the Act at Rs. 1 Cr and disallowance of interest expenses at Rs. 1,94,958/- paid on the alleged unsecured loan. 9. We notice that the disputed unsecured loan of Rs. 1 Cr was received by the assessee from the following three companies:

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) Sl. No. Name of Loan Creditor Amount (in INR) 1. Akansha Advisory Pvt. Ltd. Rs. 40,00,000/- 2. Ascent Dealmark Pvt. Ltd. Rs. 30,00,000/- 3. Wise Dealmark Pvt. Ltd. Rs. 30,00,000/- TOTAL Rs. 1,00,00,000/- 10. The above loans were taken through banking channel and interest has been paid thereon and tax at source has been deducted as per the applicable rates. It is also interesting to note that during the year the assessee company received unsecured loan of Rs. 50.18 Cr out of which only the alleged unsecured loan of Rs. 1 Cr is in dispute before us and for the remaining, ld. AO was fully satisfied. It, thus, indicates that the assessee company which is an NBFC regularly takes unsecured loans from various companies in the form of inter-corporate loans and the same are repaid from time to time. We also observe that the only basis for making the addition u/s 68 of the Act by ld. AO was that the summons issued u/s 131 of the Act were not complied. Ld. AO has nowhere doubted the creditworthiness of the documents of the assessee nor any discrepancies have been pointed out in the financial statement and other relevant details filed by the assessee in order to support the identity and creditworthiness of the loan creditors and genuineness of the transaction. Further, we notice that ld. CIT(A) has dealt the issue exhaustively and has given a finding of fact observing as follows: “4. I have carefully considered the facts of the case, written submissions made and grounds of appeal. I have also carefully gone through the impugned assessment order. After carefully considering the written submissions made and correlating the same with facts of the case and the findings of the AO, the appeal is adjudicated as under.

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) 4.1 In Ground Nos. 1 & 2, the appellant has objected to the disallowance of Rs. 1,00,00,000/- as alleged unexplained cash credit under Section 68 of the Act and consequently disallowing the corresponding interest expenditure of Rs. 1,94,958/-. In order to understand issue under consideration, it would be appropriate to bring on record the facts of the case in brief. The appellant is a non- banking financial company. In the course of its business, the appellant receives inter-corporate deposits from various entities and bodies corporate which are utilized in its business of money lending and investment. In the relevant previous year, the appellant has borrowed from bodies corporate to the tune of Rs.39.17 crores. The said borrowings were made from 10 bodies corporate. In the audited accounts as also in the tax audit report information was disclosed to the effect that the loans were taken by the appellant from bodies corporate. 4.2 In the course of assessment proceedings, the appellant was called upon to furnish the particulars of loans received during the relevant year. In response, the appellant had furnished required particulars, which inter alia included names, address and income tax PAN of each of the loan creditors. Appellant had also furnished the mode of receipt of loans and also produced copies of its own bank statement to prove that the loans were received through banking channels and not by cash. The entries in the appellant’s bank statement also established that immediately after the receipt of the loan funds, these were utilized by the appellant in its regular course of business. Based on the information furnished by the appellant, the AO observed that he had found that four of the loan creditors were managed and operated by alleged entry operator namely Mr. Jivendra Mishra and he reproduced the alleged statements recorded from them by officers of Investigation Wing. He therefore issued summons u/s 131 to all 4 loan creditors, out of which 1 loan creditor complied and the remaining 3 loan creditors only furnished the requisite details but none appeared personally before the AO. The AO thus alleged in his impugned order that the appellant was unable to prove the identity, genuineness & creditworthiness of such 3 parties from whom the loans to the extent of Rs. 1,00,00,000/- were obtained and thereby added the aforesaid sum to the taxable income of the appellant. 4.3 The details of the borrowings which are in dispute in these grounds of appeal are as under

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) Sl. Name of Loan Creditor Amount (in INR) No. 1. Akansha Advisory Pvt Ltd Rs.40,00,000/- 2. Ascent Dealmark Pvt Ltd Rs.30,00,000/- 3. Wise Dealmark Pvt Ltd Rs.30,00,000/- TOTAL Rs. 1,00,00,000/- The appellant, during the appeal proceedings, stated that in the proceedings u/s 143(3) the appellant had placed before the AO full and complete information with regard to above-mentioned fresh loans received during the year. Each of the loan creditors was regularly assessed to tax. The net owned funds of each loan creditor was several times more than the loans advanced by each of them to the appellant. The appellant had therefore argued that it had established the identity of the creditors, /creditworthiness of the creditors 86 genuineness of the transactions. Further, the appellant pointed out that the AO did not point out any cogent defect or infirmity in the documents placed on record by the appellant. At the outset the appellant submitted that out of the 10 loan creditors who had advanced loans to the extent of Rs.29.17 crores, the AO treated loans to the extent of Rs. 1,00,00,000/- received from 3 loan creditors as unexplained cash credit u/s 68 of the Act. The appellant submitted that it had furnished similar information in respect of the loans advanced to it by all the 10 loan creditors. All these loan creditors were income-tax assessees. They had furnished their audited accounts, IT Acknowledgements, loan confirmations, bank statements etc which are required in the normal course to substantiate the loan transaction. Out of 10 loan creditors, the AO has chosen to accept the genuineness of transactions and their identity and creditworthiness of 7 loan creditors who had advanced loans to the appellant. However, the AO disbelieved the identity, creditworthiness and genuineness of the remaining 3 loan creditors and accordingly made the addition of Rs. 1,00,00,000/- u/s 68 of the Act. The appellant submitted that on the same set of facts which were discernible from the assessment records in respect of all the loan creditors, the AO chose to disbelieve only 3 loan creditors and accepted the transactions with remaining 7 loan creditors. 4.4 It is relevant to mention that the AO had made enquiries u/s 131 from all the three loan creditors. Each of the loan creditors furnished complete details as requisitioned in notice u/s 131. These loan

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) creditors had furnished before the AO, copies of their Bank statements which reflected the transaction of loans advanced by them. The loan creditors had also furnished their explanations with regard to the immediate source from which payments were made to the appellant. It was evident from the Bank statements that no cash was deposited in the accounts of these loan creditors prior to encashment of cheques issued in appellant’s favour. The bank statements also substantiated that the loan creditors regularly conducted high value monetary transactions with several other persons and it was not a case where the loan creditors had financial transactions only with the appellant. Not even a remote lacuna, infirmity, falsity or defect was established or proved in the evidences placed on record nor was the Assessing Officer able to prove any falsity in the explanations furnished by the loan creditors in respect of the source and/or the source of source of the funds advanced. The explanations furnished by the loan creditors were acknowledged and remained uncontroverted by the Assessing Officer. Despite furnishing of information and documentary evidences in response to notices u/s 131 the AO did not bring on record even a single specific instance which established that the evidences put forth by the loan creditors before him were false bogus or untrue. 4.5 The only basis for addition is the statement of given by One Mr Jivendra Mishra and non-response of the directors of the three companies namely, 1. M/s Akansha Advisory Pvt Ltd, 2. Ascent Dealmark Pvt Ltd & 3. Wise Dealmark Pvt Ltd to the summons issued U/S 131 of the Act by the AO. With regard to these three loan creditors, it was alleged that these loans were accommodation entries provided by entry operator, Mr. Jivendra Mishra. The statement of this alleged entry operator is reproduced in the assessment order. Referring to this statement, it has been alleged that the loans received from these entities was bogus and has been assessed as appellant’s undisclosed income. The statement of Shri Jivendra Mishra has no relevance whatsoever in the facts of the present case. If one carefully peruses the statement of Shri Jivendra Mishra it shall be observed that there is nothing in the statement which either suggests that he had provided accommodation entries to the appellant or that the three lender companies, M/s Akansha Advisory Pvt Ltd, Ascent Dealmark Pvt Ltd & Wise Dealmark Pvt Ltd were either controlled or managed by him. There is nothing whatsoever on record or any other material or evidence, which in any manner proves that the unsecured loans received from the said three companies was not genuine or that any

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) part of the loan reached back to the appellant in any form. Further, the appellant has not been allowed any opportunity to cross examine Mr Jivendra Mishra to ascertain as to whether he had provided any such alleged accommodation entries specifically to the appellant. The AO should have specifically asked Mr Jivendra Mishra as to whether the appellant has in anyway benefitted from his activities of alleged rotation of monies or whether he had used these three companies for the purpose. The AO further should have enquired from the AO of the respective lender companies regarding the genuineness of the transactions. The fact that there are no cash deposits prior to lending of money to the appellant by the three companies and there is no evidence of so-called cash had been rotated and brought back into books of the appellant, the statement of Mr. Jivendra Mishra looses significance or no relevance or not reliable piece of evidence in arriving at conclusion that the transactions made by the companies are non- genuine and bogus. When these circumstantial evidences do not prove anything adverse, the AO simply cannot disregard the documents produced as stage managed and resort to addition on the theory of human probabilities. 4.6 On the contrary, the appellant had filed the name, complete address, PAN details, confirmation, audited financial statements and bank statements of the lenders. Genuineness of the transaction was also proved since evidences furnished proved that the loans were transacted through bank accounts of the creditors. All the loan creditors were regularly-assessed to tax and for AY 2015-16 each of the loan creditor had filed their tax returns. Each loan creditor had furnished their financial statements for the financial year 2014-15 in which transaction with the appellant was properly reflected, The appellant had paid interest to each loan creditor and taxes were deducted u/s 194A in respect of such interest. The appellant had also complied with provisions concerning filing of TDS returns. Loan creditors had disclosed interest income in their respective tax returns. Despite furnishing of information and documentary evidences in response to notices U/s 133(6) the AO did not bring on record even a single specific instance which established that the evidences put forth by the creditors before him were false bogus or untrue. None of the notices issued by the AO went non-complied with. The AO also did not bring any evidence on record to suggest that the loans received by the appellant was from any undisclosed sources nor any material was brought on record to show that the loan creditors were bogus. The AO was neither able to controvert the documentary evidences

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) filed by the appellant nor prove that the loan monies received were in- genuine or that the loan creditors were non-creditworthy. 4.7 The AO has alleged that the appellant had failed to establish the identity of the loan creditors & genuineness of the transactions on sole ground that directors of the companies did not respond to summons issued under section 131 of the Act. The AO goes on to allege that the appellant had rotated his unaccounted money through loan creditors. According to AO furnishing of corporate information pertaining to loan creditors, bank statements, annual accounts and other paperwork cannot be treated as justifiable evidence and hence the appellant was alleged to have failed in its endeavour to discharge its onus to establish the three ingredients of Section 68 of the Act. Without pointing any specific lacuna, infirmity, falsity or defect in the documents and evidences placed on record, the AO arrived at conclusion that cash deposits were made and funds were routed through loan creditors. In none of the cases, the AO however could validly prove or bring anything on record that cash deposits were made which were ultimately routed through the loan creditors. The allegation of the AO seems to have no relevance or remote connection with the jurisdictional facts of the case. The AO was also unable to point out any defect or infirmity in the details & paperwork furnished by the appellant and the documents obtained from the loan creditors. 4.8 The appellant submitted that Section 68 of the Income-tax Act, 1961 provides that any sum found credited in the year in respect of which the assessee fails to explain the nature and source shall be assessed as its undisclosed income. In the facts of the present case, both the nature & source of the loan received was fully explained by the appellant. The appellant had conclusively proved the identity, creditworthiness and genuineness of the loan creditors. The PAN details, bank account statements, financial statements and I.T. acknowledgments of all loan creditors were placed on AO’s record. The entries in the bank statement established that each loan was paid through proper banking channel. In the circumstances in terms of Sec 108 of the Indian Evidence Act, the assessee had discharged its onus of proving identity and creditworthiness of the loan creditor. The genuineness of the transaction was also established. The appellant thus had discharged the onus cast by law in proving identity and creditworthiness of each loan creditor. 4.9 It is not in dispute that the appellant had furnished all the details of all the creditor companies that were sought for by the AO. The AO Page 10 of 26

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) issued notices u/s 133(6) of the Act to all the creditor companies. All the creditors responded to notice u/s 133(6) of the Act directly by sending the requisite details to the AO. I find that all the three alleged loan creditors had duly confirmed the transactions with the appellant company. The evidences which were filed before the AO with regard to this issue are as under:- a) Income Tax Return of the loan creditors b) Audited financial statements of the loan creditor companies c) Loan confirmation letters d) Transactions with the appellant duly highlighted in the bank statement. These evidences were also filed during the course of appeal proceedings. From the aforesaid details, I find that in case of all loan creditors - a) The loan creditors are income tax assessees and had filed their income tax returns regularly. b) The loans were made out by account payee cheques. c) The loan creditors are having substantial creditworthiness in the form of free reserves and capital in their balance sheet. 4.10 As per the mandate of section 68 of the Act, the nature and source of credit in the books of the appellant company has been duly explained by the appellant. The credit is in the form of receipt of loan from the creditors. The nature of receipt towards loan is well established from the entries passed in the respective balance sheets of the companies as loans or advances as the case may be. Hence the nature of receipt is proved by the appellant beyond doubt. In respect of source of credit, the appellant has to prove the three necessary ingredients i.e. identity, genuineness of transactions and creditworthiness of loan creditors. The identity of loan creditors is proved beyond doubt by the appellant by furnishing the name, address, PAN of loan creditors together with the copies of balance sheets and income tax returns. The three loan creditors responded to the notice under section 133(6) of the Act and complied with all thew information requisitioned by the AO. The companies are regularly assessed to tax and filing returns of income. With regard to the

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) creditworthiness of loan creditors, these companies are having sufficient funds in the form of capital and reserves. These transactions are also duly reflected in the balance sheets of the loan creditors as under (in INR) Name Amount Net Worth Reflected in Note of Accounts FY 2014-15 Akansha Advisory Pvt Ltd 40,00,000 21,42,76,805 Note No. 10 Ascent Dealmark Pvt Ltd 30,00,000 32,00,61,356 Note No. 2.6 Wise Dealmark Pvt Ltd 30,00,000 48,37,52,919 Note No. 7

4.11 By this, the creditworthiness of loan creditors is also proved beyond doubt. With regard to genuineness of transactions, the monies have been directly paid to the appellant company by account payee cheques out of sufficient bank balances available in their respective bank accounts. I find that the appellant had even proved the source of money deposited into the respective bank accounts of loan creditors, which in turn had been used by them to lend to the appellant company. Hence the source of source is also proved in the instant case though the same is not required to be done by the appellant as per law. The loan creditors have confirmed the fact of giving loans to the appellant in response to notice u/s 133(6) of the Act and have also confirmed the payments which are duly corroborated with their respective bank statements and all the payments are by account payee cheques.” 11. The above finding of fact remains unrebutted by ld. D/R by placing any other contrary material on record. We have also perused the financial statements of the alleged three cash creditors and note that all the three companies have more than sufficient funds appearing in the audited balance sheet to explain the alleged cash credits, for instance Wise Dealmark Pvt. Ltd. has accumulated share capital and reserve surplus to the tune of Rs. 48.37 Cr against which the loan of Rs. 30 lakh has been received by the assessee company. In the case of the cash creditor namely

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) Akansha Advisory Pvt. Ltd. the share capital and reserve surplus are approx. 21.40 Cr whereas the loan received from this company is Rs. 40 lakh. Similarly, in the case of Ascent Dealmark Pvt. Ltd. the net worth of the company is approx. 32 Cr against which unsecured loan of Rs. 30 lakh has been given to the assessee company. We, thus, are of the considered view that the assessee has successfully explained the identity and creditworthiness of the loan creditors and genuineness of the transaction and has successfully discharged its primary onus casted upon it to explain the nature and source of the alleged sum and therefore, provisions of Section 68 of the Act have been wrongly invoked by ld. AO. Provisions of Section 68 of the Act has a direct bearing on this issue and for necessary adjudication, we reproduce below the said provision: “Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, the sum so credited may be charged to income-tax as the income of the assessee of that previous year: [Provided that] where the assessee is a company (not being a company in which the public are substantially interested), and the sum so credited consists of share application money, share capital, share premium or any such amount by whatever name called, any explanation offered by such assessee-company shall be deemed to be not satisfactory, unless— (a) the person, being a resident in whose name such credit is recorded in the books of such company also offers an explanation about the nature and source of such sum so credited; and (b) such explanation in the opinion of the Assessing Officer aforesaid has been found to be satisfactory:

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) [Provided further] that nothing contained in the first proviso [or second proviso] shall apply if the person, in whose name the sum referred to therein is recorded, is a venture capital fund or a venture capital company as referred to in clause (23FB) of section 10.” 12. From perusal of the above Section, we observe that Section 68 of the Act is invoked if any sum is found credited in the books of an assessee for which the assessee either does not offer any explanation about the nature and source thereof or the explanation offered by him is not found to be satisfactory in the opinion of the Assessing Officer. In the given case, the assessee has given the explanation and successfully discharged the primary onus casted upon it by filing the financial statements and all necessary documents and evidences of the share applicants and they are in itself sufficient to satisfy the nature and source of the alleged credit. 13. Recently, this Tribunal in the case of Mainak Suppliers Pvt. Ltd. (supra) has adjudicated similar set of facts and circumstances wherein the assessment proceedings were carried out under the directions of ld. CIT(A) u/s 263 of the Act and the issue was also the same i.e. unexplained share application money and share premium and this Tribunal after considering the facts of the case and the documents filed by the assessee and those being regularly assessed to tax, decided in favour of the assessee observing as follows: “9. We have heard the rival contentions and gone through the material placed on record. Admittedly, it is a fact on record that notices u/s. 133(6) of the Act were issued by Ld. AO to all the sixteen share subscriber companies and all of them had duly replied directly to the ld. AO, along with relevant documents and details. Copies of the

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) replies duly acknowledged under seal and stamp of the office of the Ld. AO are placed on record. We note that Ld. AO without even going through and discussing these details submitted by the sixteen subscriber companies, insisted for personal appearance to prove the identity, creditworthiness of the subscriber companies and the genuineness of the transactions. 9.1. To our mind, ld. AO could have taken an adverse view only if he could point out the discrepancies or insufficiency in the evidence and details received in his office from all the sixteen subscriber companies and also pointing out as to what further investigation was needed by him by way of recording of statement of the directors of the assessee and the subscriber companies. We draw our force from the decision of the Hon’ble Bombay High Court in the case of PCIT vs. Paradise Inland Shipping Pvt. Ltd. [2017] 84 taxmann.com 58 (Bom) wherein it was held that once the assessee has produced documentary evidence to establish the existence of the subscriber companies, the burden would shift on the revenue to establish its case. 9.2. We also draw our force from the decision of Hon’ble Jurisdictional High Court of Calcutta in the case of Crystal Network Pvt. Ltd. vs. CIT (supra) which held as under: “We find considerable force from the submissions of the learned counsel for the appellant that the Tribunal has merely noticed that since the summons issued before assessment returned unserved and no one came forward to prove. Therefore, it shall be assumed that the assessee failed to prove the existence of the creditors or for that matter creditworthiness. As rightly pointed out by the learned counsel that the CIT(Appeals) has taken the trouble of examining of all other materials and documents viz., confirmatory statements, invoices, challans and vouchers showing supply of bidi as against the advance. Therefore, the attendance of the witnesses pursuant to the summons issued in our view is not important. The important is to prove as to whether the said cash credit was received as against the future sale of the produce of the assessee or not. When it was found by the CIT(Appeal) on fact having examined the documents that the advance given by the creditors have been established the Tribunal should not have ignored this fact finding." 10. We also take note of the fact that all the share subscriber companies have filed their return of income with the department which have been either processed u/s. 143(1) of the Act for which

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) intimations have been issued or have been assessed u/s. 143(3) or 147 on substantive basis, for which the respective intimation/assessment orders are placed on record in the paper book. We also take note of the fact that all the sixteen share subscriber companies have responded to the notice issued u/s. 133(6) of the Act and Ld. AO has not bothered to discuss or point out any defect or deficiency in the documents furnished by the share subscribing companies. These evidences furnished by them have been neither controverted by the Ld. AO during the assessment proceedings nor anything substantive brought on record to justify the addition made by him. Ld. AO has simply added the amount of share capital and share premium on the ground that assessee has not produced the directors/shareholders. Ld. AO has ignored the reply given in response to notice issued u/s. 133(6) of the Act which are on record under duly acknowledged seal and stamp of his good office. From the perusal of the order of Ld. CIT(A), we note that Ld. CIT(A) has perused the evidence in the nature of documents and details and on their examination has deleted the addition made by the Ld. AO. Thus, going by the records placed by the assessee and by all the share subscribing companies in response to notices issued u/s 133(6), it can be safely held that the assessee has discharged its initial burden and the burden shifted on the ld. AO to enquire further into the matter which he failed to do so. 10.1. Ld. CIT(A) has elaborately appreciated the evidence and details placed on record and has given his factual findings, crux of which is contained in para 8.1 of his order, which is extracted below for ease of reference: “8.1. Basically the law requires documentary evidences on record in dealing with the issue of authenticity. It is not the case of the AO that necessary documentary evidences are not on record but the only major reliance placed on his action is based on non-attendance of the directors of the appellant company along with directors of subscriber companies before him u/s 131 of the Act. It is no longer res integra that such non-attendance should be considered as a factor which should be used by the AO in coming to an adverse conclusion against the appellant. On an overall analysis of the issue, I find that the AO has not made out his case with cogent material on record that the appellant could come under the purview of section 68 of the Act with regard to share capital as reflected in the balance sheet when there is no finding with any cogent material evidence that the same was

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) actually bogus in nature. It is accordingly observed that creditworthiness of the share subscribers to make investment in the share capital of the appellant company cannot be a disputed matter as per material facts on record. The aforesaid facts underlined by evidences clearly prove the identity of the share applicants, their creditworthiness and source of funds, as well as the genuineness of the transactions being investments in the share capital issued by the appellant, which was subscribed to by each of them. Thus, it is proved beyond any-doubt or dispute that the share applicants are actually found to have subscribed to the share capital issued by the appellant during the year under consideration as clearly evident not only from their respective books of accounts but also from their audited accounts filed with the income tax authorities in relation to their own income tax assessments and the sources of such funds are also explained by each of the share applicants in their replies addressed to the AO. However, the AO had not brought these indisputable facts on record but acted on his whims and fancies. It is observed that the burden which la on the appellant, in relation to section 68 of the Act, has been duly discharged by it and nothing further remains to be proved by it on the issue. Hence, I am inclined to accept the arguments tendered by the AR of the appellant in this respect. In view of the above, I have no hesitation to hold that the impugned addition made by invoking the provisions of s. 68 by the AO is not justified in the circumstances and accordingly, direct him to delete such addition of Rs.21,08,00,000/- made on this account. Thus, these grounds of the appeal are allowed.” 10.2. Further, we note that ld. CIT(A) has taken into consideration the creditworthiness of all the sixteen subscriber companies by going through the records and the net worth of each of them (refer the details tabulated above). It is also noted that all the investing companies have substantial own funds available with them to make investment in the assessee. In this respect, all the investing companies have also explained their source of funds in their reply to notices issued u/s. 133(6) of the Act. 10.3. From the perusal of the paper book and the replies filed by share subscribing companies in response to notice u/s. 133(6) of the Act, it is vivid that all the share applicants are (i) income tax assessees, (ii) they are filing their income tax returns, (iii) share application form and allotment letter is available on record, (iv) share application money was paid by account payee cheques, (v) details of the bank accounts

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) belonging to share applicants and their bank statements are on record, (vi) in none of the transactions, there are any deposit of cash before issuing cheques to the assessee, (vii) all the share applicants are having substantial creditworthiness represented by their capital and reserves. 10.4. For expressing our views as aforesaid, we draw our force also from the decision of Hon’ble jurisdictional High Court of Calcutta in the case of PCIT vs. Shree Leathers in ITAT/18/2022 (IA No. GA/02/2022) dated 14.07.2022 wherein Hon’ble High Court succinctly dealt with the aspect whether notices u/s. 133(6) of the Act are issued which are duly acknowledged or responded but ignored by the AO leads to perversity in the assessment order. Relevant extract from the said decision is reproduced as under: “…Bearing the above legal principles in mind, if we examine the case on hand, it is clear that the assessing officer issued show cause notice only in respect of one of the lender M/s. Fast Glow Distributors. The assessee responded to the show cause notice and submitted the reply dated 22.12.2017. The documents annexed to the reply were classified under 3 categories namely: to establish the identity of the lender, to prove the genuineness of the transactions and to establish the creditworthiness of the lender. The assessing officer has brushed aside these documents and in a very casual manner has stated that mere filing PAN details, balance sheet does not absolve the assessee from his responsibility of proving the nature of transaction. There is no discussion by the assessing officer on the correctness of the stand taken by the assessee. Thus, going by the records placed by the assessee, it could be safely held that the assessee has discharged his initial burden and the burden shifts on the assessing officer to enquire further into the matter which he failed to do. In more than one place the assessing officer used the expression "money laundering." We find such usage to be uncalled for as the allegations of money laundering is a very serious allegations and the effect of a case of money laundering under the relevant Act is markedly different. Therefore, the assessing officer should have desisted from using such expression when it was never the case that there was any allegations of money laundering. Paragraph 5.4 and 5.5 of the assessment order are all personal perception and opinion of the assessing officer which needs to be ITAT 18 OF 2022 ignored. Much reliance was placed on the statement of Shri Ashish Kumar Agarwal, which statement has been extracted in full in the assessment order and it cannot be

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) disputed that there is no allegation against the assessee company in the said statement. There is no evidence brought on record by the assessing officer to connect the said entry operator with the loan transaction done by the assessee. Therefore, the statement is of little avail and could not have been the basis for making allegations. The assessing officer ignored the settled legal principle and in spite of the assessee having offered the explanation with regard to the loan transaction, no finding has been recorded as regards the satisfaction on the explanation offered by the assessee. Therefore, the assessing officer ignored the basic tenets of law before invoking his power under Section 68 of the Act. Fortunately, for the assessee, CIT(A) has done an elaborate factual exercise, took into consideration, the creditworthiness of the 13 companies the details of which were furnished by the assessee. More importantly, the CIT noted that all these companies responded to the notices issued under Section 133 (6) of the Act which fact has not been denied by the assessing officer. On going through the records and the net worth of the lender companies, the CIT has recorded the factual findings that the net worth of those companies is in crores of rupees and they have declared income to the tune of Rs. 45,00,000/- and 75,00,000/-. Therefore, the assessing officer if in his opinion found the explanation offered by the assessee to be not satisfactory, he should have recorded so with reasons. We find that there is no discussion on the explanation offered ITAT 18 OF 2022 by the assessee qua, one of the lenders. Admittedly, the assessee was not issued any show cause notice in respect of other lenders. However, they are able to produce the details before the CIT(A) who had in our view rightly appreciated the facts and circumstances of the case. As pointed out earlier, the assessing officer brushed aside the explanation offered by the assessee by stating that merely filing PAN details, balance sheet does not absolve the assessee from his responsibilities of proving the nature of transactions. It is not enough for the assessing officer to say so but he should record reasons in writing as to why the documents which were filed by the assessee along with the reply dated 22.12.2017 does not go to establish the identity of the lender or prove the genuineness of the transaction or establish the creditworthiness of the lender. In the absence of any such finding, we have to hold that the order passed by the assessing officer was utterly perverse and rightly interfered by the CIT(A). The Tribunal re-appreciated the factual position and agreed with the CIT(A). The tribunal apart from taking into consideration, the legal effect of the statement of Ashish Kumar Agarwal also took note of the fact that the notices which were Page 19 of 26

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) issued by the assessing officer under Section 133 (6) of the Act to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal in the form of a paper book. These materials were available on the file of the assessing officer and there is no discussion on this aspect. Thus, we find that the tribunal rightly dismissed the appeal filed by the revenue.” 11. In respect of reliance placed by the revenue on the decision of Hon’ble Supreme Court in the case of PCIT vs. NRA Iron & Steel Pvt. Ltd. 412 ITR 161 (SC), we note that Hon’ble Supreme Court in para 8.2 of the said decision has made the following observations: “8.2 As per settled law, the initial onus is on the Assessee to establish by cogent evidence the genuineness of the transaction, and credit- worthiness of the investors under Section 68 of the Act. The assessee is expected to establish to the satisfaction of the Assessing Officer CIT v. Precision Finance (P) Ltd. [1995] 82 Taxman 31/[1994]208 ITR 465 (Cal.): Proof of Identity of the creditors; Capacity of creditors to advance money; and Genuineness of transaction This Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invoking Section 68. If the Assessee is not able to provide a satisfactory explanation of the nature and source, of the investments made, it is open to the Revenue to hold that it is the income of the assessee, and there would be no further burden on the revenue to show that the income is from any particular source." 11.1. Further, in para 9 of the said decision, Hon'ble Supreme Court has observed as under:

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) "9. The Judgments cited hold that the Assessing Officer ought to conduct an independent enquiry to verify the genuineness of the credit entries. In the present case, the Assessing Officer made an independent and detailed enquiry, including survey of the so-called investor companies from Mumbai, Kolkata and Guwahati to verify the credit-worthiness of the parties, the source of funds invested, and the genuineness of the transactions. The field reports revealed that the share-holders were either non-existent, or lacked credit-worthiness." 11.2. Thereafter, Hon'ble Supreme Court summed up the principles which emerged by deliberating upon various case laws as under: "11. The principles which emerge where sums of money are credited as Share Capital/Premium are: i. The assessee is under a legal obligation to prove the genuineness of the transaction, the identity of the creditors, and credit-worthiness of the investors who should have the financial capacity to make the investment in question, to the satisfaction of the AO, so as to discharge the primary onus. ii. The Assessing Office is duty bound to investigate the credit- worthiness of the creditor/subscriber, verify the identity of the subscribers, and ascertain whether the transaction is genuine, or these are bogus entries of namelenders. iii. If the enquiries and investigations reveal that the identity of the creditors to be dubious or doubtful, or lack credit-worthiness, then the genuineness of the transaction would not be established. In such a case, the assessee would not have discharged the primary onus contemplated by Section 68 of the Act.” 11.3. Hon'ble Supreme Court, thus, held that once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness of the subscribers, then, AO is duty bound to conduct an independent enquiry to verify the same. However, as noted above, ld. AO in this case has not made any independent enquiry to verify the genuineness of the transactions. Assessee, having furnished all the details and documents before the ld. AO and the ld. AO has not pointed out any discrepancy or insufficiency in the said evidences and details furnished by the assessee before him. As observed above, the assessee having Page 21 of 26

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) discharged its initial burden casted upon him to furnish the evidences to prove the identity and creditworthiness of the share subscribers and genuineness of the transaction, it shifted on the ld. AO to examine the evidences furnished and even make independent inquiries and thereafter to state that on what account he was not satisfied with the details and evidences furnished by the assessee by confronting with the same to the assessee. In view of this, the aforesaid decision of the Hon'ble Supreme Court in the case of PCIT vs. NRA Iron and Steel Pvt. Ltd., in our humble view, is not applicable to the facts and circumstances of the case in hand. 12. Considering the facts and circumstances of the case and the material placed on record, we find that assessee has discharged its onus to prove the identity and creditworthiness of the share subscribing companies and the genuineness of the transactions. Accordingly, considering these facts and in the light of the judicial precedents referred above, we find no reason to interfere with the fact- based findings given by the Ld. CIT(A) and uphold his decision to delete the addition made by the Ld. AO towards share capital and share premium u/s. 68 of the Act. Accordingly, grounds taken by the revenue in this respect are dismissed. 13. In the result, appeal of the revenue is dismissed.” 14. So far as reliance placed by ld. D/R on the judgment of the Hon’ble Supreme Court in the case of PCIT, (Central)-1, Kolkata vs. NRA Iron & Steel Pvt. Ltd. reported in 412 ITR 161, we find that the same is not applicable on the facts of the present case. We find that the Hon’ble Supreme Court in para 8.2 of the said decision has made the following observations:

“8.2 As per settled law, the initial onus is on the Assessee to establish by cogent evidence the genuineness of the transaction, and credit- worthiness of the investors under Section 68 of the Act. The assessee is expected to establish to the satisfaction of the Assessing Officer CIT v. Precision Finance (P.) Ltd. [1995] 82 Taxman 31/[1994] 208 ITR 465 (Cal.): Proof of Identity of the creditors;

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) Capacity of creditors to advance money; and Genuineness of transaction This Court in the land mark case of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an inquiry, and call for more details before invoking Section 68. If the Assessee is not able to provide a satisfactory explanation of the nature and source, of the investments made, it is open to the Revenue to hold that it is the income of the assessee, and there would be no further burden on the revenue to show that the income is from any particular source.” 14.1. Further, in para 9 of the said decision, the hon’ble Supreme Court has observed as under: “9. The Judgments cited hold that the Assessing Officer ought to conduct an independent enquiry to verify the genuineness of the credit entries. In the present case, the Assessing Officer made an independent and detailed enquiry, including survey of the so-called investor companies from Mumbai, Kolkata and Guwahati to verify the credit-worthiness of the parties, the source of funds invested, and the genuineness of the transactions. The field reports revealed that the share-holders were either non-existent, or lacked credit-worthiness.” 14.2. Thereafter the Hon’ble Supreme Court summed up the principles which emerged after deliberating upon various case laws as under: “11. The principles which emerge where sums of money are credited as Share Capital/Premium are: i. The assessee is under a legal obligation to prove the genuineness of the transaction, the identity of the creditors, and credit-worthiness of the investors who should have the

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) financial capacity to make the investment in question, to the satisfaction of the AO, so as to discharge the primary onus. ii. The Assessing Officer is duty bound to investigate the credit- worthiness of the creditor/subscriber, verify the identity of the subscribers, and ascertain whether the transaction is genuine, or these are bogus entries of name-lenders. iii. If the enquiries and investigations reveal that the identity of the creditors to be dubious or doubtful, or lack credit- worthiness, then the genuineness of the transaction would not be established. In such a case, the assessee would not have discharged the primary onus contemplated by Section 68 of the Act.” 15. The Hon’ble Supreme court, thus, has held that once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness of the subscribers, then the AO is duty bound conduct to conduct an independent enquiry to verify the same. However, as noted above, ld. AO in this case has not made any independent enquiry to verify the genuineness of the transactions. The assessee having furnished all the details and documents before ld. AO and ld. AO has not pointed out any discrepancy or insufficiency in the said evidences and details furnished by the assessee before him. As observed above, the assessee having discharged initial burden upon him to furnish the evidences to prove the identity and creditworthiness of the share subscribers and genuineness of the transaction, the burden shifted upon ld. AO to examine the evidences furnished and even make independent inquiries and thereafter to state that on what account he was not satisfied with the details and evidences furnished by the assessee and confronting with the same to the assessee. In view of this, the

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I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) aforesaid decision of the Hon’ble Supreme Court in the case of PCIT vs. NRA Iron and Steel Pvt. Ltd. (supra), in our humble view, is not applicable to the facts and circumstances of the case in hand. 16. We, therefore, respectfully following the ratio laid down by the Hon'ble Courts in the judgment referred herein above deciding in favour of the assessee(s) and on considering the facts of the instant case, fail to find any infirmity in the finding of ld. CIT(A) deleting the impugned addition made u/s 68 of the Act at Rs. 1 Cr. Since the addition u/s 68 of the Act has been deleted, therefore, the assessee is eligible to claim the interest expenses of Rs. 1,94,958/- which ld. CIT(A) has already allowed. Thus, ground nos. 1, 2 & 3 raised by the Revenue are dismissed. 17. As regards ground nos. 4 & 5 are concerned, they relate to disallowance made u/s 14A of the Act read with Rule 8D of the Income Tax Rules, 1962. We observe that the assessee has earned exempt income of Rs. 7,36,767/- and in the computation of income of the assessee has suo-moto disallowed expenditure of Rs. 27,99,056/- u/s 14A of the Act. Ld. AO computed the disallowance u/s 14A of the Act at Rs. 3,29,27,727/-. Ld. CIT(A) deleted the said disallowance referring to the exempt income earned by the assessee. We fail to find any consistency in the finding of ld. CIT(A), since for the year under appeal the disallowance u/s 14A of the Act could not have exceeded exempt income earned by the assessee and for this proposition we draw support from the decision of Hon'ble Delhi High Court in the case of Principal Commissioner of Income-tax (Central) vs. Era Infrastructure (India) Ltd. reported in [2022] 141 taxmann.com 289 (Delhi). Therefore, Page 25 of 26

I.T.A. No.: 96/KOL/2021 Assessment Year: 2015-16 M/s. Edmond Finvest Pvt. Ltd. (Earlier known as Edmond Textiles Pvt. Ltd.) since the assessee has suo moto offered disallowance of Rs. 27,99,056/- which is more than the exempt income by the assessee, no further disallowance was called for u/s 14A of the Act. Thus, ground nos. 4 & 5 raised by the Revenue are dismissed. 18. Ground no. 6 general in nature which needs no adjudication. 19. In the result, the appeal filed by the Revenue is dismissed. Kolkata, the 16th May, 2023 Sd/- Sd/- [Sanjay Garg] [Manish Borad] Judicial Member Accountant Member Dated: 16.05.2023 Bidhan (P.S.) Copy of the order forwarded to: 1. M/s. Edmond Finvest Pvt. Ltd., (Earlier known as Edmond Textiles Pvt. Ltd.), 225C, Alpe Court, AJC Bose Road, Minto Park, Kolkata-700 020. 2. DCIT, CC-1(4), Kolkata. 3. CIT(A)-24, Kolkata. 4. CIT- 5. CIT(D/R), Kolkata Benches, Kolkata. //True copy // By order

Assistant Registrar ITAT, Kolkata Benches Kolkata

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