Section 68 Addition Cannot Rest on Non-Filing of Creditor’s Return: Patna HC

Patna High Court: Section 68 addition unsustainable; ITAT wrongly enhanced onus despite established identity & bank trail

The Patna High Court set aside the Income Tax Appellate Tribunal’s order restoring an addition under Section 68 of the Income Tax Act and reinstated the relief granted by the CIT(A). The assessee had received ₹1.91 crore through banking channels and furnished PAN details, confirmations, ledger accounts, bank statements, and income tax returns of the creditor for other years. While the Assessing Officer treated the amount as unexplained cas

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