Addition not justified for lower income declaration by Investors in their Tax return

ACIT Vs Supreme Placement Services (P) Ltd. (ITAT Delhi)

Conclusion: Addition on account of unexplained share capital/premium was not justified as AO merely doubted the financial capacity of the Investors because they had reported low income in their return of income. This could not be the sole basis to doubt the explanation of assessee. It might be suspicion of the AO only without bringing any evidence on record.

Held: A search under section 132 was cond

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