Once the assessee has proven the identity of the creditors and the amounts have been taken through account payee cheques, the small share capital contributed by such persons does not deserve to be added as an unexplained credit merely because the assessee failed to give a Permanent Account Number, as held by DelTrib in Jas Gold Finlease Ltd v ITO — In favour of: The assessee (partly).
Additional evidence — Admission of additional evidence submitted by the assessee is justified where opportunity was granted to the AO but he did not make any comments on merit.
Decided on: 16 September 2011.
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