Issues: Whether a trust whose earlier applications for registration had been rejected may file a subsequent application for registration under Section 12AB of the Income-tax Act, 1961, and whether the later application could be rejected as non-maintainable solely because earlier rejection orders had attained finality.

Analysis: The statutory inquiry on an application for registration is confined to the genuineness of the trust's activities and its compliance with other laws material to achieving its objects. The Act contains no restriction barring a trust from making a subsequent application before the same authority where it satisfies the conditions for registration. Failure to appeal earlier rejection orders does not extinguish that statutory entitlement. A registration, if ultimately granted on a later application, can operate only from the date of that latest application and not from the date of an earlier application.

Conclusion: The later application could not be treated as non-maintainable, non est, or void ab initio merely because earlier rejection orders were not appealed; this finding is in favour of the assessee.

Final Conclusion: The registration matter was restored for fresh determination on the statutory requirements after affording the assessee a reasonable opportunity to submit supporting material.

Ratio Decidendi: In the absence of an express statutory bar, rejection of an earlier registration application does not preclude a trust from filing a fresh application for registration, which must be assessed on the statutory criteria applicable to that application.

Issues: Whether the school could be independently assessed on its alleged surplus when it claimed to be a constituent of a registered educational society and its income had already been reflected by that society.

Analysis: The Revenue had accepted for an earlier assessment year that the school formed part of the educational society. For the relevant year, neither the Assessing Officer nor the appellate authority verified the school's claim that its income was included in the society's accounts. No contrary evidence, material factual distinction, or change in circumstances was established to justify a departure from the earlier accepted position. The principle of consistency consequently applied notwithstanding that each assessment year is a separate proceeding and res judicata does not strictly govern taxation.

Conclusion: The school's claim that it was part of the educational society was accepted, and the assessment and addition made in its separate hands could not be sustained.

Issues: Whether criminal proceedings for dishonour of cheque should be quashed on the grounds of disputed service of statutory notice, the applicant's incarceration, repeated presentation of the cheque, and impleadment of a proprietorship concern instead of its proprietor.

Analysis: The questions regarding the applicant's incarceration, service of notice, and circumstances of presentation and dishonour of the cheque require evidentiary consideration at trial and constitute matters of defence. The statutory presumption applicable to cheque dishonour proceedings remains available at this stage. A proprietorship concern and its proprietor are not distinct in the manner of a company; therefore, impleadment of the proprietorship concern did not invalidate the complaint.

Conclusion: Quashing was declined; the applicant may contest the proceedings at trial by raising all legal and factual defences.

Issues: Whether the spouse of a deceased cheque payee, without an endorsement or authority establishing entitlement, can issue a statutory demand notice and maintain a complaint for cheque dishonour.

Analysis: The statutory scheme confines the demand and complaint for cheque dishonour to the payee or holder in due course. A holder must be entitled in their own name both to possess the cheque and to recover its amount. The complainant was not named as payee, had no endorsement in her favour, and did not establish authority through a succession certificate, probate, letters of administration, or other judicial determination enabling her to give the drawer a full discharge. The Magistrate issued process on the incorrect premise that the cheques had been issued to the complainant, without determining whether she satisfied the statutory eligibility requirement. This constituted an express legal bar to cognizance and warranted exercise of inherent jurisdiction.

Conclusion: The deceased payee's spouse was neither the payee nor a holder in due course and could not maintain the cheque-dishonour complaints without lawful authority establishing her entitlement.

Issues: (i) Whether rejection of registration under section 12AB on alleged statutory non-compliances and financial discrepancies was sustainable without conclusive evidence linking them to non-genuine charitable activities; (ii) Whether an existing section 12AB registration could be treated as cancelled or superseded while deciding a renewal application without following the statutory cancellation procedure; (iii) Whether rejection of approval under section 80G(5), consequential upon rejection of section 12AB registration, could stand.

Issue (i): Whether rejection of registration under section 12AB on alleged statutory non-compliances and financial discrepancies was sustainable without conclusive evidence linking them to non-genuine charitable activities.

Analysis: Registration enquiry requires examination of the objects, genuineness of activities and compliance with laws material to the stated objects; it cannot become a roving inquiry into administration, accounts or governance absent a direct bearing on charitable character or genuineness. The educational activities were not found to be sham or non-genuine. No competent authority under the Haryana Private Universities Act, 2006 or the Foreign Contribution (Regulation) Act, 2010 had determined any violation. Accounting discrepancies alone could not justify refusal unless they established non-genuine activities or non-charitable purposes. However, the fund flows, the character and retention of contributions collected by the sponsoring body, scholarships, possible nexus with admissions, and actual financial and operational autonomy required objective verification.

Conclusion: The rejection of registration was set aside for fresh, evidence-based adjudication after comprehensive enquiry and due opportunity to the assessee.

Issue (ii): Whether an existing section 12AB registration could be treated as cancelled or superseded while deciding a renewal application without following the statutory cancellation procedure.

Analysis: Cancellation of an operative registration is governed by the separate mechanism under section 12AB(4), requiring a specified violation and compliance with the prescribed procedure, including opportunity of hearing. No independent cancellation proceedings had been initiated.

Conclusion: Any observation treating the existing registration as cancelled, superseded or ineffective was beyond jurisdiction and unsustainable; the cancellation question was remitted for action only in accordance with section 12AB(4).

Issue (iii): Whether rejection of approval under section 80G(5), consequential upon rejection of section 12AB registration, could stand.

Analysis: The section 80G(5) matter arose from the same factual circumstances and rested on the section 12AB rejection that had been set aside for reconsideration.

Conclusion: The section 80G(5) matter was also remitted for fresh adjudication.

Final Conclusion: The registration and approval questions remain open for determination upon proper verification of the funding arrangements, institutional autonomy, statutory compliance and the genuineness of activities, without reliance on assumptions or presumptions.

Ratio Decidendi: Registration cannot be refused on unverified allegations of regulatory breaches or accounting irregularities unless they objectively establish that the institution's activities are not genuine or are inconsistent with its charitable objects; cancellation of existing registration requires adherence to the distinct statutory procedure.

Issues: Whether registration under Section 12AB could be granted where the Trust's objects were alleged to be confined to the welfare and business interests of its members rather than the public at large.

Analysis: The main objects provided for educational, cultural, social, medical, developmental, disaster-relief, agricultural, women-empowerment, water-conservation and sports activities for the public at large, including the poor, needy and backward classes, without discrimination. The objects also prohibited distribution of profits or dividends to members and commercial operation. The incidental objects concerning industry-related committees and public facilities did not displace the charitable character of the principal objects. Isolated incidental objects could not justify treating the Trust as a members-only welfare association when its principal purposes were directed towards public benefit.

Conclusion: Registration under Section 12AB was rightly granted to the Trust; no substantial question of law arose. The issue is decided in favour of the assessee.

Issues: (i) Whether the cash deposits during demonetisation were taxable as unexplained cash credits; (ii) Whether the addition for the outstanding credit balance was sustainable; (iii) Whether the cessation of input VAT credit was allowable as business expenditure.

Issue (i): Whether the cash deposits during demonetisation were taxable as unexplained cash credits.

Analysis: The cash deposits were stated to arise from recorded cash sales. While the explanation and supporting books could not be wholly disregarded, the disproportionate rise in cash sales immediately before demonetisation remained insufficiently explained. A restricted lump-sum addition was considered appropriate on the peculiar facts.

Conclusion: The addition is restricted to Rs. 3.50 lakh, in favour of the assessee to that extent.

Issue (ii): Whether the addition for the outstanding credit balance was sustainable.

Analysis: The assessee furnished confirmation, ledger account and supporting material concerning the creditor. The mere absence of a response to the statutory notice, particularly when the creditor's name had changed, did not displace the documentary material establishing the credit.

Conclusion: The addition for the outstanding credit balance is deleted, in favour of the assessee.

Issue (iii): Whether the cessation of input VAT credit was allowable as business expenditure.

Analysis: As the unclaimed input VAT formed part of the purchase cost, its debit under the identified expense head did not alter its revenue character. The amount was allowable as business expenditure.

Conclusion: The disallowance of input VAT credit is deleted, in favour of the assessee.

Final Conclusion: The taxable income for the relevant year requires recomputation after restricting the cash-credit addition and granting relief for the creditor balance and input VAT expenditure; the consequential set-off of eligible brought-forward loss is to be given effect.

Issues: (i) Whether exemption for capital gains on sale of the residential flat was allowable on deposit under the Capital Gains Accounts Scheme; (ii) Whether the agricultural land transferred was a capital asset because it lay within the prescribed municipal distance; (iii) Whether capital gains on the residential flat required recomputation after allowing indexation.

Issue (i): Whether exemption for capital gains on sale of the residential flat was allowable on deposit under the Capital Gains Accounts Scheme.

Analysis: The bank statement and certificate established that the deposit was made under the Capital Gains Accounts Scheme. The documentary evidence was available before the assessing and appellate authorities and supported compliance with the deposit requirement.

Conclusion: Exemption under section 54 was allowable and the disallowance was deleted, in favour of the assessee.

Issue (ii): Whether the agricultural land transferred was a capital asset because it lay within the prescribed municipal distance.

Analysis: The record included material indicating a distance exceeding 11 kilometres from the municipality, while the taxable character of the land depended on whether it was within 8 kilometres of the municipal limits. This factual question required verification.

Conclusion: The question whether the agricultural land was a capital asset was remitted for fresh verification and adjudication, in favour of the assessee to that extent.

Issue (iii): Whether capital gains on the residential flat required recomputation after allowing indexation.

Analysis: The computation sheet had not allowed indexation in calculating capital gains from the residential flat. Since the capital-gains issue relating to that property had already been decided, the computation required fresh determination.

Conclusion: The computation was remitted with a direction to allow indexation benefit while calculating capital gains, in favour of the assessee.

Final Conclusion: The section 54 disallowance stands deleted, while the taxability of the agricultural land and consequential capital-gains computation require fresh assessment in accordance with the directions.

Ratio Decidendi: Documentary proof of a qualifying capital-gains-scheme deposit supports section 54 relief, while the status of agricultural land as a capital asset must be determined upon verified municipal-distance facts.

Issues: Whether the Directorate of Revenue Intelligence and customs authorities have jurisdiction to investigate and adjudicate alleged breach of EPCG licence conditions, notwithstanding issuance of an export obligation discharge certificate by the licensing authority.

Analysis: The allegations concerned use of unconnected third-party shipping bills and false declarations for obtaining discharge of export obligation, resulting in alleged loss of customs duty. This was distinct from an allegation of misrepresentation in obtaining the licence. A discharge certificate issued by the licensing authority does not bar customs authorities from investigating breach of conditions attached to a duty-exempt import where fraud, concealment, misrepresentation or misdeclaration is alleged. No statutory bar to the customs proceedings was shown. The challenge to a show-cause notice was therefore not fit for interference in writ jurisdiction, while the petitioners could place their defence before the adjudicating authority.

Conclusion: The customs authorities have jurisdiction to continue proceedings from the show-cause-notice stage concerning the alleged violation of EPCG licence conditions; the issue is against the assessee.

Issues: (i) Whether notional rental income could be assessed contrary to the operative rent arrangement and evidence of actual rent received; (ii) Whether booking advances carried in the books could be taxed as cessation or bogus liabilities; (iii) Whether an opening unsecured-loan balance could be added as an unexplained cash credit; (iv) Whether the disallowances of bad debt, repairs and maintenance expenses, and other business expenses were sustainable; (v) Whether penalty under Section 271AAC(1) of the Income-tax Act, 1961 could be levied while the validity of the underlying assessment was pending before the High Court.

Issue (i): Whether notional rental income could be assessed contrary to the operative rent arrangement and evidence of actual rent received.

Analysis: The later modified memorandum of understanding was supported by the tenant's confirmation, rent advices, invoices, bank credits and Form 26AS. The earlier arrangement relied upon for computing higher monthly rent had not been acted upon. The consistent acceptance of rent declared under the modified arrangement in earlier years also supported the assessee's position.

Conclusion: The addition for notional rental income was deleted in favour of the assessee.

Issue (ii): Whether booking advances carried in the books could be taxed as cessation or bogus liabilities.

Analysis: The advance from one purchaser was an opening balance received against sale of shop space, and its character as a booking advance was confirmed by the purchaser. The other advances represented booking rights transferred by the original allottees to another entity; failure to pass a consequential book entry did not establish cessation of liability. No deduction had been shown to have been allowed in respect of these capital advances.

Conclusion: The additions relating to both booking advances were deleted in favour of the assessee.

Issue (iii): Whether an opening unsecured-loan balance could be added as an unexplained cash credit.

Analysis: Section 68 applies to a sum credited in the books during the relevant previous year. The disputed loan was shown through the ledger as a brought-forward opening balance and was not credited during the assessment year.

Conclusion: The addition of the opening loan balance under Section 68 of the Income-tax Act, 1961 was deleted in favour of the assessee.

Issue (iv): Whether the disallowances of bad debt, repairs and maintenance expenses, and other business expenses were sustainable.

Analysis: The outstanding rental debt had been written off in the accounts, satisfying the conditions for bad-debt deduction. The repairs and maintenance claim was supported by material placed before the Assessing Officer, who identified no defect. Pooja expenses and service-tax interest were routine business expenditure, whereas interest on tax deducted at source was not allowable.

Conclusion: The bad-debt and repairs disallowances, and the disallowance of routine business expenses other than interest on tax deducted at source, were deleted in favour of the assessee; the disallowance of interest on tax deducted at source was sustained against the assessee.

Issue (v): Whether penalty under Section 271AAC(1) of the Income-tax Act, 1961 could be levied while the validity of the underlying assessment was pending before the High Court.

Analysis: The writ petition challenging the assessment jurisdiction for alleged non-issuance of notice under Section 143(2) of the Income-tax Act, 1961 had been admitted and remained pending. Since the foundation of the assessment had not attained finality, the penalty issue remained debatable and unconcluded.

Conclusion: The penalty was deleted in favour of the assessee.

Final Conclusion: The principal income additions and the penalty were removed, while the limited disallowance relating to interest on tax deducted at source remained intact.

Ratio Decidendi: An opening balance cannot be assessed as unexplained cash credit for a year in which no credit arises, and a penalty founded on an assessment whose jurisdictional validity remains pending adjudication cannot be sustained.

Issues: Whether accused persons in cheque-dishonour proceedings may obtain expert analysis of cheque entries where the complainant specifically asserts that those entries were written by the accused in the complainant's presence.

Analysis: Although the identity of the person who filled in cheque entries is ordinarily immaterial once execution is established and the statutory presumption operates, it becomes materially relevant where the complainant's case specifically rests on an assertion that the accused personally wrote the entries. Proof that the handwriting is not that of the accused would directly affect the credibility and acceptability of the complainant's evidence concerning execution and issuance of the cheques. The accused must therefore be afforded an opportunity to obtain expert evidence on that factual assertion.

Conclusion: The accused are entitled to have the impugned cheques sent for expert analysis of the entries, in their favour.

Ratio Decidendi: Where a complainant specifically attributes the writing of cheque entries to the accused, handwriting comparison is relevant to test the credibility of that assertion and cannot be denied merely because a statutory presumption arises upon execution of the cheque.

Issues: (i) Whether conversion of polythene rolls into printed, cut, sealed and shaped polythene bags amounted to manufacture or merely job work; (ii) Whether the extended period of limitation was validly invoked.

Issue (i): Whether conversion of polythene rolls into printed, cut, sealed and shaped polythene bags amounted to manufacture or merely job work.

Analysis: Section 2(f) of the Central Excise Act, 1944 covers processes incidental or ancillary to completion of a manufactured product. The applicable test is whether the process results in a commercially distinct and marketable article having a different name, character or use. The rolls underwent printing, shaping, cutting, sealing and packing, resulting in polythene bags that were distinct from the input rolls and marketable as such. The presence of the customers' logos, supply of inputs by them, and return of waste and scrap did not alter the character of the activity.

Conclusion: The conversion activity amounted to manufacture, not job work, and the polythene bags were liable to central excise duty upon clearance. This issue was decided against the assessee.

Issue (ii): Whether the extended period of limitation was validly invoked.

Analysis: Filing ST-3 returns and paying service tax on conversion charges did not disclose or discharge the separate central excise liability arising from manufacture; ST-3 returns were distinct from excise returns. As the goods were cleared to manufacturers of exempt final products, the appellant was liable for excise duty on clearance of the bags. The failure to pay that duty was treated as suppression warranting invocation of the extended period.

Conclusion: Invocation of the extended period of limitation was valid. This issue was decided against the assessee.

Final Conclusion: The conversion process attracted central excise duty and the demand founded on the extended limitation period was sustained.

Ratio Decidendi: A process that transforms polythene rolls into marketable bags with a distinct name, character and use constitutes manufacture, notwithstanding that inputs are supplied by another person and the finished bags bear that person's logo.

Issues: Whether a notice for reassessment for Assessment Year 2015-16, issued following a search conducted during Financial Year 2024-25, was barred by limitation under the ten-year computation applicable to search-related proceedings.

Analysis: The six-year period under Section 153A(1)(b) is calculated by reference to assessment years immediately preceding the search assessment year and therefore excludes that year. The extended ten-year period under Explanation 1 to Section 153A employs distinct language, requiring computation from the end of the assessment year relevant to the previous year of search. Giving effect to this separate formulation, the search assessment year must be included as the first year of the ten-year block. For a search in Financial Year 2024-25, Assessment Year 2025-26 is the first year and Assessment Year 2016-17 is the tenth year; Assessment Year 2015-16 lies outside the permissible period.

Conclusion: The reassessment notice for Assessment Year 2015-16 was time-barred and was quashed.

Issues: Whether a reassessment can sustain additions concerning an item not forming the recorded reasons for reopening when the income forming the basis of those reasons was accepted without addition.

Analysis: The reassessment was initiated to verify share application money received from a specified entity. The Assessing Officer accepted that transaction and made no addition on the recorded reason. The additions for an unsecured loan from another entity and related interest were founded on separate information discovered during reassessment. Applying the rule governing the scope of reassessment, such other income could be assessed only after assessing or reassessing the income that formed the recorded basis for reopening; otherwise, a fresh reassessment notice was required.

Conclusion: The reassessment additions were beyond the permissible scope of reassessment and were invalid, in favour of the assessee.

Ratio Decidendi: Where no addition is made in respect of income forming the recorded reason for reopening, the Assessing Officer cannot independently assess another income in that reassessment without issuing a fresh statutory notice.

Issues: (i) Whether investment in a flat under construction qualifies as construction of a residential house for exemption of capital gains, notwithstanding delay in completion and registration attributable to the developer; (ii) Whether exemption can be allowed where it was omitted from the return but supported by complete material furnished during assessment proceedings.

Issue (i): Whether investment in a flat under construction qualifies as construction of a residential house for exemption of capital gains, notwithstanding delay in completion and registration attributable to the developer.

Analysis: Allotment and staged payments for a flat under construction are substantively construction of a residential house through the developer, rather than purchase of a completed house. The contemporaneous booking and payment evidence established that the capital gains were committed to the new residential project within the prescribed period. The assessee had discharged the obligations within his control; delayed completion and conveyance by the developer could not defeat the beneficial exemption intended to promote reinvestment in residential housing.

Conclusion: The assessee was entitled to exemption under Section 54 of the Income-tax Act, 1961; developer-caused delay in completion or registration did not disqualify the claim.

Issue (ii): Whether exemption can be allowed where it was omitted from the return but supported by complete material furnished during assessment proceedings.

Analysis: Although the return did not disclose the capital-gains claim, the detailed computation, booking documents, payment particulars and balance-sheet evidence were furnished before the Assessing Officer. The restriction on entertaining a claim otherwise than through a revised return is confined to the Assessing Officer and does not limit the appellate authorities' powers to admit and grant a legally admissible claim. A procedural omission cannot override established substantive entitlement.

Conclusion: The assessee's omission to claim the exemption in the return did not bar the appellate authorities from granting the lawful exemption.

Final Conclusion: The denial of the capital-gains exemption was unsustainable, and the addition made on that basis was deleted.

Ratio Decidendi: Where an assessee timely and substantially invests capital gains in an under-construction residential property, exemption cannot be denied for developer-caused delay; appellate authorities may grant a substantively valid claim notwithstanding its omission from the return.

Issues: Whether the assessee's rights in the flat, surrendered during the relevant year, were a long-term or short-term capital asset for capital-gains computation.

Analysis: Contemporaneous reservation and transfer documents, the developer's confirmation, bank records and ledger material established acquisition of the allotment rights in financial year 2006-07. Subsequent accounting entries and adjustments in a consolidated ledger for multiple flats did not displace that evidence. An allottee's right in property is a valuable capital asset, and its holding period is reckoned from allotment or reservation; later payments are consequential.

Conclusion: The surrendered rights constituted a long-term capital asset, and the gain was assessable as long-term capital gain with indexation benefit, in favour of the assessee.

Issues: Whether delayed electronic furnishing of Form 10CCB disentitles an assessee from deduction under section 80-IA where the return claiming that deduction was filed within the prescribed time.

Analysis: For the relevant assessment year, sections 80A(5) and 80AC required that the deduction be claimed in a return furnished within the due date under section 139(1), and those conditions stood satisfied. The requirement concerning Form 10CCB was treated as directory for the period in question; the subsequent statutory change making its furnishing mandatory operated only from 01.04.2020. The report had been furnished to the CPC with the rectification application before completion of substantive assessment proceedings. The rule governing an exemption under Chapter III was inapplicable because a deduction under Chapter VI-A operates in a distinct statutory domain.

Conclusion: Delayed furnishing of Form 10CCB did not bar the section 80-IA deduction for the relevant assessment year; the claimed deduction was required to be granted.

Issues: Whether reassessment could validly be initiated under sections 147 and 148 of the Income-tax Act, 1961 on the basis of material emanating from a third-party search, rather than under section 153C of that Act.

Analysis: The information forming the basis of the notice was derived from the appraisal report and consequential investigation following a search conducted in the case of third parties. The reference to survey proceedings was part of that search-based investigation and did not constitute an independent basis for reassessment. The notice also contained inconsistent descriptions of the alleged transaction, referring both to bogus purchases and to receipt of funds, indicating absence of an independent determination of the alleged escapement. Sections 153A and 153C constitute a special search-assessment code overriding the general reassessment machinery under sections 147 and 148. Where proceedings are founded on material unearthed in a third-party search, recourse to section 153C is mandatory, subject to its statutory conditions.

Conclusion: The assumption of jurisdiction under section 148 was invalid; the notice under section 148, the order under section 148A(d), and the consequential reassessment order were quashed in favour of the assessee.

Issues: Whether penalty for furnishing inaccurate particulars of income could validly be imposed under Section 271(1)(c) by invoking Explanation 1, despite the assessment order having initiated penalty under both limbs of that provision.

Analysis: The assessment order initiated penalty for both furnishing inaccurate particulars and concealment of income. The subsequent notice and penalty order identified furnishing inaccurate particulars as the charge, but invoked Explanation 1 to Section 271(1)(c). Explanation 1 creates a deeming consequence that additions or disallowances represent income whose particulars have been concealed; it does not govern the separate charge of furnishing inaccurate particulars. The charge ultimately invoked and the statutory basis relied upon were therefore incongruent.

Conclusion: The penalty was invalid in law and was deleted, in favour of the assessee.

Issues: (i) Whether the share application money received from ten identified applicants was unexplained cash credit; (ii) Whether the unsecured loans received from eight lenders were unexplained cash credits.

Issue (i): Whether the share application money received from ten identified applicants was unexplained cash credit.

Analysis: For seven applicants, confirmations, income-tax returns, financial statements and bank statements established identity, availability of funds and receipt through banking channels. For the remaining three applicants, confirmations, returns and balance sheets showed sufficient owned funds. For Assessment Year 2011-12, the subsequently introduced requirement to establish the source of the source of share application money was inapplicable. Once the assessee supplied the material establishing the primary ingredients under Section 68, the burden shifted to the Assessing Officer, who made no independent enquiry to disprove it.

Conclusion: The entire share application money of INR 1 crore was satisfactorily explained and could not be added under Section 68, in favour of the assessee.

Issue (ii): Whether the unsecured loans received from eight lenders were unexplained cash credits.

Analysis: The additional material comprising lender confirmations, bank statements, income-tax acknowledgements and, where available, financial statements established the lenders' identity, funds and banking-channel transactions. The loan repayments through banking channels, including repayments preceding reassessment, corroborated the genuineness of the borrowings. The Revenue did not rebut the appellate findings with independent adverse material, and no adequate enquiry had been undertaken in respect of most lenders.

Conclusion: The unsecured loans of INR 3,65,70,000 were satisfactorily explained and their deletion under Section 68 was upheld, in favour of the assessee.

Final Conclusion: The additions for both the share application receipts and unsecured loan credits were deleted on the assessee having discharged its statutory evidentiary burden.

Ratio Decidendi: For a pre-2013 share capital credit, evidence establishing the subscriber's identity, financial capacity and banking-channel transaction discharges the assessee's burden under Section 68; where loan credits and repayments are supported by banking records and the Revenue produces no contrary material after enquiry, the credits cannot be treated as unexplained.