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    <description>Share capital and share premium credits were held to be explained where the assessee established the identity, creditworthiness and genuineness of the share applicants with confirmations, returns, balance sheets and other supporting material. The assessee was a genuine operating manufacturing company and gave a commercial justification for issuing shares at premium. The investor companies were registered entities, responded to notices, and had adequate shareholder funds with explained source of funds. As the Revenue relied on suspicion and adverse inference without contrary evidence, the primary burden under section 68 was treated as discharged and the addition was deleted.</description>
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      <description>Share capital and share premium credits were held to be explained where the assessee established the identity, creditworthiness and genuineness of the share applicants with confirmations, returns, balance sheets and other supporting material. The assessee was a genuine operating manufacturing company and gave a commercial justification for issuing shares at premium. The investor companies were registered entities, responded to notices, and had adequate shareholder funds with explained source of funds. As the Revenue relied on suspicion and adverse inference without contrary evidence, the primary burden under section 68 was treated as discharged and the addition was deleted.</description>
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