Share application money addition upheld under Section 68 due to unproven investor identity and transaction genuineness
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....ITAT upheld addition of unexplained share application money under Section 68, rejecting assessee's discharge of onus regarding investor identity, creditworthiness, and transaction genuineness. Tribunal found entire share application money received in cash without proper transaction dates filed before authorities constituted self-serving evidence. Director's non-appearance for examination despite partial statement recording, combined with ongoing company irregularity proceedings, established transactions as make-believe scheme lacking genuineness. ITAT distinguished criminal proceedings requiring proof beyond reasonable doubt from assessment proceedings governed by preponderance of probabilities, human probabilities test, and surrounding cir.........