₹50 Lakh Credit Without Source or Capacity Fails Section 68 Test; ITAT Upholds Addition

Prestigious Enterprises Pvt. Ltd. Vs ACIT (ITAT Delhi) Pursuant to earlier ITAT remand for de novo adjudication, AO accepted ₹1 crore compensation as capital receipt but again added ₹50 lakh u/s 68, noting deficiencies in confirmation from creditor M/s Treatwell Investments Pvt. Ltd., absence of company stamp, no cheque details, bank entry not reflecting payer identity, & failure to explain immediate source. CIT(A) confirmed addition, holding that Assessee failed to establish identity, creditworthiness & genuineness of transaction, particularly as creditor’s return showed NIL inc...