HC upheld section 68 addition as Assessee failed to prove 3 conditions

Rupal Jain Vs CIT (Allahabad High Court) Considering the provision of Section 68 that the assessee has to prove three conditions i.e. (i) identity of the creditor; (2) capacity of such creditor to advance money; and (iii) genuineness of the transactions. If all the aforesaid three conditions are proved, the burden shifts on the revenue to prove that the amount belong to the assessee. However, the assessee cannot be asked to prove source of source or the origin of origin. In the present case it is evident that the assessee though has disclosed the source of the deposit but could not establish t...