Capital contribution from partners do not amount to unexplained cash credits.
ITAT Guwahati held that
“We also examine the return filed by the assessee for AY 2012-13 and observe from the details of persons who were partners in the assessee firm as on 31.03.2012 that SDPL is a partner in the assessee firm. During the course of assessment proceedings, the AO noted that assessee has received Rs.1,67,07,000/- as capital contribution from its partner SDPL. It is abundantly clear that AO has not applied his mind on the information received and reopened the assessment in a mechanical manner and that too on borrowed satisfaction without recording his own satisfaction…..”
