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Section 68 Proviso Not Retrospective; Assessee Must Bear Burden of Proof Under Income Tax Act.

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....Addition made u/s 68 - onus to discharge the burden so cast upon assessee - The legislature did not introduce the proviso to section 68 of the Act with retrospective effect nor does the proviso so introduce states that it was introduce ‘for removal of doubts’ or that it is ‘declaratory’, therefore, it is not open to give it to retrospective effect.....

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Section 68 Proviso Not Retrospective; Assessee Must Bear Burden of Proof Under Income Tax Act.