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manner provided under section 144, after holding that adequate opportunity of being heard had been afforded to the assessee.

5. During the assessment proceedings, the Assessing Officer noticed that the assessee had credited Rs. 91,00,00,000/- to the Reserve and Surplus Account without routing the amount through the Profit and Loss Account. When called upon to explain, the assessee stated that the entry was passed on ill advice, represented liquidated damages, involved no actual receipt or payment, and was an incorrect book entry sought to be rectified through revised financial statements filed beyond the time limit. The Assessing Officer rejected the explanation, holding that the original audited financial statements filed with the return and the Registrar of Companies could not be disregarded, that revised statements filed beyond time without a valid revised return were not acceptable in view of Goetze (India) Ltd. v. CIT (284 ITR 323), and that the assessee failed to establish the nature and source of the credit. The credit was treated as an artificial inflation of equity and added as unexplained cash credit under section 68.