Onus of proving nature and source of receipt lies on the assessee

VEL Software Limited Vs DCIT (ITAT Pune) Facts- The AO found during the year under consideration, share capital of the company was increased from Rs.3,25,80,000/- to 12,55,80,000/- showing an increase of Rs.9,30,00,000/-. On being asked to explain, it was contended that the increase in share capital was contributed by ten shareholders in amounts ranging from Rs.60,00,000/- to Rs.1,25,00,000/-. Various enquiries have been conducted by the department which have been detailed in the assessment order. One pertinent point which has been brought out is that all the ten shareholders who subscribed to...