Mere transaction through banking channel not sufficient to prove genuineness

Hillman Properties Pvt. Ltd. Vs ITO (ITAT Delhi)

Merely showing that transactions were carried out through Banking channel in the facts and circumstances of the case is not sufficient to prove the genuineness of the transaction in the matter. Courts and Tribunals have to Judge the evidence before them by applying the test of human probability. If the said test is applied in this matter, it is clearly established that assessee failed to prove identity of the accommodation entry providers, their creditworthiness and genuine of the transaction in the matte

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