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ITAT upheld addition of unexplained share application money under Section 68, rejecting assessee's discharge of onus regarding investor identity, creditworthiness, and transaction genuineness. Tribunal found entire share application money received in cash without proper transaction dates filed before authorities constituted self-serving evidence. Director's non-appearance for examination despite partial statement recording, combined with ongoing company irregularity proceedings, established transactions as make-believe scheme lacking genuineness. ITAT distinguished criminal proceedings requiring proof beyond reasonable doubt from assessment proceedings governed by preponderance of probabilities, human probabilities test, and surrounding circumstances standard. Despite pending SIT verdict potentially providing criminal relief, Tribunal confirmed CIT(A)'s order applying lower civil standard of proof appropriate for income tax assessments, dismissing assessee's grounds and sustaining Section 68 addition.
ITAT upheld addition of unexplained share application money under Section 68, rejecting assessee's discharge of onus regarding investor identity, creditworthiness, and transaction genuineness. Tribunal found entire share application money received in cash without proper transaction dates filed before authorities constituted self-serving evidence. Director's non-appearance for examination despite partial statement recording, combined with ongoing company irregularity proceedings, established transactions as make-believe scheme lacking genuineness. ITAT distinguished criminal proceedings requiring proof beyond reasonable doubt from assessment proceedings governed by preponderance of probabilities, human probabilities test, and surrounding circumstances standard. Despite pending SIT verdict potentially providing criminal relief, Tribunal confirmed CIT(A)'s order applying lower civil standard of proof appropriate for income tax assessments, dismissing assessee's grounds and sustaining Section 68 addition.
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