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The ITAT upheld additions under sections 68 and 69A against a dissolved firm due to unexplained credit transactions in its bank account. The tribunal held that continued operation of the bank account post-dissolution indicates the firm's ongoing existence for all practical purposes. Consequently, the entity remains liable to explain credits despite its claim of dissolution. The assessee failed to discharge the burden of proof by providing a satisfactory explanation for the credits. Reliance was placed on the Supreme Court precedent affirming that failure to adequately explain and substantiate credits justifies additions under section 68. The appeal was dismissed, and the additions were sustained against the assessee.
The ITAT upheld additions under sections 68 and 69A against a dissolved firm due to unexplained credit transactions in its bank account. The tribunal held that continued operation of the bank account post-dissolution indicates the firm's ongoing existence for all practical purposes. Consequently, the entity remains liable to explain credits despite its claim of dissolution. The assessee failed to discharge the burden of proof by providing a satisfactory explanation for the credits. Reliance was placed on the Supreme Court precedent affirming that failure to adequately explain and substantiate credits justifies additions under section 68. The appeal was dismissed, and the additions were sustained against the assessee.
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