TaxTMI 
TaxTMI 
2026 (1) TMI 1691
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...., Adv. Mr. Amit Sharma, Adv. For the Respondent : Mr. Avra Mazumder, Adv. Ms. Alisha Das, Adv. Ms. Sreeja Mukherjee, Adv. Ms. Rupomita Ghosh, Adv. ORDER The Court: Learned counsel appearing for the appellant/revenue has suggested the following substantial questions of law: "i) Whether on the facts and circumstances of the case, the Learned Tribunal was justified in law to delete ....
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....Section 68 of the Income Tax Act, 1961 by ignoring the judicial precedents that the onus is on the assessee to explain and establish the source of funds which in the instant case, the assessee has failed to do ? iv) Whether on the facts and in the circumstances of the case, the Learned Tribunal was justified in law to delete the addition made under Section 68 of the Income Tax Act, 1961 w....
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....ction was through banking channels or by account payee instrument as held by the Jurisdictional High Court in the case of Principal Commissioner of Income Tax Vs. BST Infratech Ltd. reported in [2024] 161 taxmann.com 668 (Calcutta) ?" This Court perused the memorandum of appeal, application for stay and the impugned judgment of the Tribunal dated 26.11.2024. The Tribunal held that "The Hon'ble ....
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....are subscribers and genuineness of the transaction, the burden shifted upon the Assessing Officer to examine the evidences furnished and even made independent inquiries and thereafter to state that on what account he was not satisfied with the details and evidences furnished by the assessee and confronting with the same to the assessee. In view of this, even applying the ratio laid down by the Hon....