Taxpayer Rights to Challenge Section 147 Proceedings and Prove Share Capital Validity Under Income Tax Act Sections 263 and 68.

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....Entitlement to challenge the validity of initiation of proceedings u/s 147 in which challenged the validity of order passed u/s 263 - the assessee is always obliged to prove the receipt of share capital with premium etc. to the satisfaction of the AO, failure of which calls for addition u/s 68 of the Act. - AT....