MITSU INDUSTRIES LTD. Vs. DY. C.I.T.

JUDGEMENT

(1.) BEING aggrieved and dissatisfied with the impugned judgment and order dated 29.01.2004 passed by the Income Tax Appellate Tribunal, Ahmedabad 'C' Bench (Tribunal) in Income Tax Appeal No. 2023/AHD/1998 for the assessment year 1992 -93, the assessee has preferred the present tax appeal.

(2.) THE facts leading to the present tax appeal in a nutshell are set out as under:

(3.) MR . Sudhir Mehta, learned advocate appearing for the revenue submitted that the Tribunal is justified in passing the impugned order inasmuch as the assessee failed to prove the genuineness of the transactions under consideration and the creditworthiness of the loaner. He submitted that inspite of repeated opportunities given to the assessee the assessee could not explain reasonable cause. Mr. Mehta submitted that the Tribunal was justified in relying upon the Calcutta High Court decision in the case of M/s. Shanker Industries v. CIT Calcutta reported in : 114 ITR 689.