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Unexplained trade credits must be supported by proof of source, creditor identity and mode of payment; where these are not satisfactorily established, the receipt loses its character as business income and is taxable under Section 68 as income from other sources. The assessee must also show that the receipt is derived from the eligible industrial undertaking before claiming deduction under Sections 80-IA/80-IB. An unexplained credit not shown as business receipt cannot be linked to eligible profits or enjoy the deduction. The credits were therefore treated as taxable unexplained income, and the deduction claim failed.
Unexplained trade credits must be supported by proof of source, creditor identity and mode of payment; where these are not satisfactorily established, the receipt loses its character as business income and is taxable under Section 68 as income from other sources. The assessee must also show that the receipt is derived from the eligible industrial undertaking before claiming deduction under Sections 80-IA/80-IB. An unexplained credit not shown as business receipt cannot be linked to eligible profits or enjoy the deduction. The credits were therefore treated as taxable unexplained income, and the deduction claim failed.
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