Tax Authorities Misapply Section 56(2)(viib) on Share Capital Advance; No Evidence of Unaccounted Money Found.

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....Income from other sources - advance against share capital received during the year - The tax authorities invoked the provision u/s 56(2)(viib) without bringing on record whether the investment received by the assessee are genuine or not. We notice that the provision introduced by the legislature in order to curb the practice of generation and circulation of unaccounted money. In the current case, the tax authorities have not brought on record any generation or circulation of unaccounted money. - AT....