Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Burden of proof for unexplained credits lies on the assessee in whose books the entries appear; the assessee must prove identity, creditworthiness and genuineness of creditors, failing which additions are sustainable. Evidence from search records and sworn statements established that the assessee functioned as a conduit for accommodation entries, so AO's additions treating credits as unexplained were restored. The CIT(A)'s view that protective additions fall because beneficiaries faced substantive additions was rejected; liability for unexplained credits attaches independently to the booked assessee, and consequential additions for parallel undisclosed cash routing were upheld.
Burden of proof for unexplained credits lies on the assessee in whose books the entries appear; the assessee must prove identity, creditworthiness and genuineness of creditors, failing which additions are sustainable. Evidence from search records and sworn statements established that the assessee functioned as a conduit for accommodation entries, so AO's additions treating credits as unexplained were restored. The CIT(A)'s view that protective additions fall because beneficiaries faced substantive additions was rejected; liability for unexplained credits attaches independently to the booked assessee, and consequential additions for parallel undisclosed cash routing were upheld.
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