https://www.taxtmi.com/caselaws?id=436064 Section 68 could not be invoked on the entire receipts from circular transactions where the assessee acted only as a conduit for accommodation entries. The admitted facts showed that sale proceeds were immediately passed on against corresponding purchases, leaving only a commission margin, so the source of the credit entries stood explained and the statutory precondition for treating them as unexplained cash credits was not met. In these circumstances, only the real income embedded in the arrangement, namely commission, was liable to tax, not the gross purchases or receipts. A precedent dealing with a different factual setting of bogus purchases by a beneficiary was held inapplicable, and the first appellate authority's view was upheld. en-us Wed, 22 Mar 2023 00:00:00 +0530 Mon, 03 Apr 2023 15:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436064 Section 68 could not be invoked on the entire receipts from circular transactions where the assessee acted only as a conduit for accommodation entries. The admitted facts showed that sale proceeds were immediately passed on against corresponding purchases, leaving only a commission margin, so the source of the credit entries stood explained and the statutory precondition for treating them as unexplained cash credits was not met. In these circumstances, only the real income embedded in the arrangement, namely commission, was liable to tax, not the gross purchases or receipts. A precedent dealing with a different factual setting of bogus purchases by a beneficiary was held inapplicable, and the first appellate authority's view was upheld. Case-Laws Income Tax Wed, 22 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436064