Section 68 additions merely for minimum income declared by parties not sustainable

ACIT Vs Pakkeer Tulkarnai- Gulam Alam Shah (ITAT Chennai) The AO has made additions towards loans taken from five parties as unexplained cash credit u/s.68 of the Act. According to the AO, although the assessee proved identity of the creditors and genuineness of transactions, but failed to prove creditworthiness of the parties. The AO has doubted creditworthiness of the parties mainly on the basis of ITRs filed by them for the relevant assessment years. According to the AO, they had declared less income or loss for the relevant assessment years, which is insufficient to explain amount of loan ...