Section 68 Addition Unjustified: Assessee Proves Share Capital Source; AO Fails to Disprove Evidence, Lacks Justification.

Addition u/s 68 - Unexplained share capital - both the nature & source of the share application and premium received by it was fully explained by the assessee. - assessee had discharged its onus to prove the identity, creditworthiness and genuineness of the share applicants, thereafter the onus shifted to AO to disprove the materials placed before him. Without doing so, the addition made by the AO is based on conjectures and surmises cannot be justified - AT .....

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