https://www.taxtmi.com/caselaws?id=327820 The HC upheld the Commissioner's revision under Section 263, finding no perversity in reopening the case suo motu under Section 147. The court held that unaccounted money purportedly received as share application money could be examined under Section 68 if the assessee fails to satisfactorily establish its source. Mere receipt by cheque or registration of applicants as companies does not prove genuineness. The assessing officer erred in not investigating further despite evidence suggesting a façade and lack of creditworthiness of share applicants. The court rejected the assessee's contention that the source of source is irrelevant and found the transaction prima facie not genuine, concluding the assessing officer's order was erroneous and prejudicial to revenue. The decision was against the assessee. en-us Fri, 13 May 2016 00:00:00 +0530 Wed, 11 Mar 2026 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327820 The HC upheld the Commissioner's revision under Section 263, finding no perversity in reopening the case suo motu under Section 147. The court held that unaccounted money purportedly received as share application money could be examined under Section 68 if the assessee fails to satisfactorily establish its source. Mere receipt by cheque or registration of applicants as companies does not prove genuineness. The assessing officer erred in not investigating further despite evidence suggesting a façade and lack of creditworthiness of share applicants. The court rejected the assessee's contention that the source of source is irrelevant and found the transaction prima facie not genuine, concluding the assessing officer's order was erroneous and prejudicial to revenue. The decision was against the assessee. Case-Laws Income Tax Fri, 13 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327820