To avail benefit of ‘peak credit’ theory Assessee needs to explain all transactions

CIT Vs M/S. JRD Stock Brokers Pvt. Ltd (Delhi High Court)

The peak credit worked out by the Assessee was on the basis that the principle of peak credit would apply, notwithstanding the failure of the Assessee to explain each of the sources of the deposits and the corresponding destination of the payment without squaring them off. That is not permissible in law.

ITAT cannot proceed merely on the basis of accountancy, overlooking the settled legal position that peak credit i

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