Unexplained Credits Require Current-Year Evidence, While Recorded Debtors and Opening Balances Cannot Be Treated as Income
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....Brought-forward capital cannot be assessed as current-year income merely because an originally reported balance-sheet figure is erroneous; a demonstrable accounting correction supported by accepted prior-year records is permissible absent evidence of fresh unexplained accretion. Alleged on-money for immovable property requires cogent proof of actual payment, and a retracted vendor statement or unconnected cash deposits does not establish ownership of unexplained money. Section 68 requires a credit arising in the relevant year, so aggregate closing creditor balances, internal appropriations, prior-year liabilities and supported chit liabilities cannot be taxed without component-wise examination. Recorded sundry debtors are debit receivables, not cash credits or unrecorded investments. On these principles, the four additions were deleted.....
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