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of ITAT held that the assessee's subscription scheme 'Kuber Dhanvarsha' involving deposits ranging from Rs. 1,250 to Rs. 10,000 was fraudulent. The tribunal found the depositor addresses cryptic and unverifiable, with no genuine intention to return funds. The deposits were characterized as income under Section 28, not Section 68, due to lack of depositor genuineness proof. The tribunal concluded the scheme was designed to defraud innocent depositors, and the entire deposit collection constitutes taxable ill-gotten income. Consequently, the ITAT sustained the tax authorities' proposed additions and dismissed the assessee's appeal.
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