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    <title>2023 (2) TMI 633 - ITAT DELHI</title>
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    <description>Share capital and share premium were treated as unexplained income under section 68 because the assessee failed to rebut the Assessing Officer&#039;s findings that the receipts were accommodation entries routed through entry providers. Mere banking channels and supporting documents were held insufficient where surrounding circumstances, investigation material, and human probability showed the transactions were not genuine. On that basis, the related commission expenditure was also treated as unexplained under section 69C. The additions were therefore sustained.</description>
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      <title>2023 (2) TMI 633 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=434118</link>
      <description>Share capital and share premium were treated as unexplained income under section 68 because the assessee failed to rebut the Assessing Officer&#039;s findings that the receipts were accommodation entries routed through entry providers. Mere banking channels and supporting documents were held insufficient where surrounding circumstances, investigation material, and human probability showed the transactions were not genuine. On that basis, the related commission expenditure was also treated as unexplained under section 69C. The additions were therefore sustained.</description>
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