Accommodation entries: AO cannot make addition without showing that explanation of Assessee is not satisfactory or incorrect

ITO Vs. Shreedham Construction Pvt Ltd (ITAT Mumbai) Section 68 casts the initial burden of proof on the assesse to show prima facie and to explain the nature and source of credit found in its When the statute places the burden of proof in income tax cases on the tax payer, it is understood to be only the initial burden. When the tax payer explains the credit by providing evidence of identity, confirmation and credit worthiness, the burden shifts on the revenue to show that the explanation is not satisfactory or incorrect. In the case of credit as share capital by corporate entity, whose exist...