Section 68 additions cannot be made merely on doubts, conjectures or surmises

ITO Vs. Ambika Metalchem Impex P. Ltd. (ITAT Mumbai)

In the present case, we find that the assessee has duly discharged the initial onus of proving the identity of the investors, creditworthiness of the transactions and genuineness of the transactions. Notices issued u/s 133(6) have been responded to. In such a scenario, the onus to dislodge the assessee’s claim, in our opinion, was shifted back to Ld. AO and he was duty bound to investigate the case further. However, the facts on record nowhere establishes that such furth

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