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    <title>2021 (12) TMI 977 - ITAT AHMEDABAD</title>
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    <description>Production of PAN, return details, bank statements and financial statements is insufficient under section 68 where surrounding circumstances show the share capital and premium credits are not genuine. The Tribunal applied the test of human probabilities and looked beyond the documents, noting the shares were issued at a very high premium, transferred soon after at a much lower value, and involved entities controlled by the same person. On those facts, the credits were treated as a colourable device to introduce unaccounted money, and the addition under section 68 was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=416211</link>
      <description>Production of PAN, return details, bank statements and financial statements is insufficient under section 68 where surrounding circumstances show the share capital and premium credits are not genuine. The Tribunal applied the test of human probabilities and looked beyond the documents, noting the shares were issued at a very high premium, transferred soon after at a much lower value, and involved entities controlled by the same person. On those facts, the credits were treated as a colourable device to introduce unaccounted money, and the addition under section 68 was upheld.</description>
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