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    <title>2023 (4) TMI 1467 - ITAT KOLKATA</title>
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    <description>Section 68 cannot be applied to share capital and share premium merely because the subscribers&#039; directors did not personally appear, where the assessee has produced primary evidence of identity, creditworthiness and genuineness. Documentary material such as confirmations, financial statements, bank details and source-of-funds records, together with subscriber responses to notices and demonstrated net worth, was treated as sufficient to discharge the initial onus. In the absence of any specific discrepancy or adverse material gathered by the Assessing Officer, the burden shifted to the Revenue to make meaningful enquiry. On that basis, the addition was not sustainable and was deleted.</description>
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