DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT
In the result, Revenue’s appeal is dismissed
ITA 48/SRT/2021[2017-18]Status: DisposedITAT Surat25 May 2022AY 2017-18
Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee
Section 132Section 132(1)Section 143(3)Section 14ASection 153ASection 153CSection 158BSection 254(1)
9. On merit, the Ld. AR of the assessee submits that during assessment as well as before Ld. CIT(A), the assessee furnished complete evidence to prove the genuineness of transaction, identity of party and creditworthiness of the lender. The Assessing Officer made addition on peak credit instead of making addition of alleged bogus unsecured loan