https://www.taxtmi.com/caselaws?id=774903 The ITAT Ahmedabad upheld the AO's addition under Section 68 for unexplained share application money received by the assessee company. The assessee failed to establish identity, creditworthiness of investors, and genuineness of transactions involving accommodation entries. The CIT(A)'s deletion based on conduit theory was rejected as unsustainable. The tribunal found the assessee retained control and benefit of funds without proving agency arrangement or commission income. Despite claims of being a conduit for entry operator, the assessee couldn't establish contractual obligation to hold funds for others. The Revenue's appeal was allowed entirely, restoring the AO's order treating amounts as unexplained income. en-us Thu, 10 Jul 2025 00:00:00 +0530 Wed, 16 Jul 2025 08:17:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774903 The ITAT Ahmedabad upheld the AO's addition under Section 68 for unexplained share application money received by the assessee company. The assessee failed to establish identity, creditworthiness of investors, and genuineness of transactions involving accommodation entries. The CIT(A)'s deletion based on conduit theory was rejected as unsustainable. The tribunal found the assessee retained control and benefit of funds without proving agency arrangement or commission income. Despite claims of being a conduit for entry operator, the assessee couldn't establish contractual obligation to hold funds for others. The Revenue's appeal was allowed entirely, restoring the AO's order treating amounts as unexplained income. Case-Laws Income Tax Thu, 10 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774903