Section 68 cannot be applied where Assessee discharges onus to prove receipt of share capital along with premium

Brief about the case The assessee is a private Company and has issued new shares of Rs.23,50,000 along with share premium of Rs.2,11,50,000.The assessee was asked to furnish the details of all shareholders along with name, address PAN and amount of capital introduced. From the details provided by the assessee, AO observed that the registered office and place of assessee’s business was in Lucknow, whereas all the 15 companies who have invested their money are from Kolkata. Out of which 12 companies are operating from four same addresses. AO issued letter u/s 133(6) of the Act to all alleged s...