Assessee Proving Three Ingredients U/S 68 Shifts Burden to AO: ITAT Pune

DCIT Vs Meridian Chem Bond Private Limited (ITAT Pune)

Does Proving the Three Main Ingredients by Assessee U/S 68 Shift the Burden of Proof On AO?

Assessee is a company that duly files its return of income. The Revenue carried a search in case of another group concern & it was discovered that it was engaged in the business of providing accommodation entries by way of bogus sales/ purchases/ loans & advances. Assessee was found to be one of the beneficiaries of these transactions. Hence, AO reopened the assessment by issuing notice u/s 148. Loans taken from the search

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