https://www.taxtmi.com/caselaws?id=212822 Share application money can escape addition under section 68 where the assessee produces primary evidence of the subscriber's identity, PAN, bank details, confirmations and banking trail; the Revenue must then conduct meaningful inquiry and cannot rely on suspicion, non-service of notices or unexplained cash deposits alone. Reassessment under sections 147 and 148 requires the Assessing Officer's independent application of mind; mechanical reliance on investigation-wing information or borrowed satisfaction does not establish a valid belief of escapement. Remand is appropriate only where verification or cross-examination remains genuinely necessary and not to cure the department's failure to investigate. en-us Fri, 23 Dec 2011 00:00:00 +0530 Mon, 01 Jun 2026 10:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212822 Share application money can escape addition under section 68 where the assessee produces primary evidence of the subscriber's identity, PAN, bank details, confirmations and banking trail; the Revenue must then conduct meaningful inquiry and cannot rely on suspicion, non-service of notices or unexplained cash deposits alone. Reassessment under sections 147 and 148 requires the Assessing Officer's independent application of mind; mechanical reliance on investigation-wing information or borrowed satisfaction does not establish a valid belief of escapement. Remand is appropriate only where verification or cross-examination remains genuinely necessary and not to cure the department's failure to investigate. Case-Laws Income Tax Fri, 23 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212822