Gumani Ram Siri Ram v. CIT

98 ITR 337High Court1975#5330 most cited

What is Gumani Ram Siri Ram v. CIT authority for?

Section 68 applies to all credit entries, regardless of who they are in the name of, and the assessing officer can add such sums as income if they are found to be not genuine after inquiry.

22

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Gumani Ram Siri Ram v. CIT · Section 68 · unexplained credit · credit entries · genuineness of transaction · onus of proof · CIT v. Gumani Ram Siri Ram · 98 ITR 337

Sections most often in play

Section 68Section 147Section 131Section 133(6)Section 142(1)Section 144Section 148Section 2(12)

Issues it is cited on

onus of proofsection 44adshare application moneysection 44addition u/s 68income-tax officergenuineness of the transactionundisclosed incomesection 133unexplained cash creditsection 68section 133(6)

Judgments citing Gumani Ram Siri Ram v. CIT

SHREE DURGA JEWELLERS,JAWAHAR NAGAR JAIPUR vs. AO CIRCLE 4 JAIPUR, CR BUILDING JAIPUR

In the result, the appeal of the assessee is allowed

ITA 33/JPR/2025[2017-18]Status: DisposedITAT Jaipur29 Apr 2025AY 2017-18
For Appellant: Shri Suhani Meharwal, CAFor Respondent: Shri Anup Singh, Addl. CIT
Section 143(1)Section 143(2)Section 143(3)Section 68

…d\ncredit under section 68 of the Act.\n8.10 In the cases where credit entry has been made in the books of the assessee,\nthe ambit of Section 68 is wide and inclusive. Provision applies to all credit entries.\nIn the case of Gumani Ram Siri Ram v. CIT [1975] 98 ITR 337 (Punj. &Har.), it was\nheld that the language of Section 68 shows that it is general in nature and applies\nto all credit entries in whomsoever name they may stand, that is, whether in the\nname of the assessee or a third party.\n8.11 The Assessing Officer when starts enquiry, specifically to satisfy himself/\nherself of the source of such credit,…

ITO,WARD-24(1), NEW DELHI vs. SUN INTRASTATE PVT. LTD., NEW DELHI

In the result, the appeals of the Revenue are dismissed

ITA 1470/DEL/2023[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Ms. Deepti Chandola, Sr. DR
Section 131Section 133(6)Section 142(1)Section 147Section 148Section 68

…word “Sum” used here in the section is very exhaustive in nature. The sum credited into the account shall be of any from and nature. It applied to all the credits by whatever the name being called. This was laid down in the case of G.R. Siri Ram v. CIT [1975] 98 ITR 337 (P&H). The ultimate aim of the Court was to keep the intent of the legislature alive. The word “Books” is defined under the Section 2 (12) of the Income Tax Act, 1961. The existence of the books is the foremost condition under this act. In V.C. Shukla vs. CBI [1998] 3 SCC 410, the Supreme Court has given a wider connotation of the term “Book". It…

ITO,WARD-24(1), NEW DELHI vs. SUN INTRASTATE PVT. LTD., NEW DELHI

In the result, the appeals of the Revenue are dismissed

ITA 1469/DEL/2023[2016-17]Status: DisposedITAT Delhi02 Jul 2024AY 2016-17

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Ms. Deepti Chandola, Sr. DR
Section 131Section 133(6)Section 142(1)Section 147Section 148Section 68

…word “Sum” used here in the section is very exhaustive in nature. The sum credited into the account shall be of any from and nature. It applied to all the credits by whatever the name being called. This was laid down in the case of G.R. Siri Ram v. CIT [1975] 98 ITR 337 (P&H). The ultimate aim of the Court was to keep the intent of the legislature alive. The word “Books” is defined under the Section 2 (12) of the Income Tax Act, 1961. The existence of the books is the foremost condition under this act. In V.C. Shukla vs. CBI [1998] 3 SCC 410, the Supreme Court has given a wider connotation of the term “Book". It…

ITO, WARD-1, NARNAUL vs. ASHOK KUMAR GUPTA, NARNAUL

In the result, the appeal filed by the Revenue is dismissed

ITA 944/DEL/2020[2009-10]Status: DisposedITAT Delhi17 May 2024AY 2009-10

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar

Section 144Section 44ASection 69

…it shown in the name of Sh. Surinder Kumar. In spite of a clear-cut finding of fact recorded by all the authorities, the appellant has sought to challenge the same by raising the substantial questions of law as has been referred to above"; Gumani Ram Siri Ram 98 ITR 337(P&H); Sat Parakash Ram Naranjan. 100 ITR 130(P&H) "Now the contention of the appellant is that assuming that he had failed to establish the case put forward by him, it does not follow as a matter of law that the amounts in question were income received or accrued during the previous year, that it was the duty of the department to adduce evidence t…

ITO, WARD-1, NARNAUL vs. ASHOK KUMAR GUPTA, NARNAUL

In the result, the appeal filed by the Revenue is dismissed

ITA 943/DEL/2020[2008-09]Status: DisposedITAT Delhi17 May 2024AY 2008-09

Bench: Shri Kul Bharat & Dr.B.R.R.Kumar

Section 144Section 44ASection 69

…it shown in the name of Sh. Surinder Kumar. In spite of a clear-cut finding of fact recorded by all the authorities, the appellant has sought to challenge the same by raising the substantial questions of law as has been referred to above"; Gumani Ram Siri Ram 98 ITR 337(P&H); Sat Parakash Ram Naranjan. 100 ITR 130(P&H) "Now the contention of the appellant is that assuming that he had failed to establish the case put forward by him, it does not follow as a matter of law that the amounts in question were income received or accrued during the previous year, that it was the duty of the department to adduce evidence t…

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 753/CHANDI/2022[AY 2019-20]Status: DisposedITAT Chandigarh03 May 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 115BSection 133ASection 143(2)Section 143(3)Section 68Section 69Section 69A

…pplicable to the case of the assessee as the credit is there in the capital account of the firm and the assessee has no justification to explain its source or nature. The Hon'ble High Court of Punjab & Haryana in the case of Gumani Ram Siri Ram vs. CIT [1975] 98 ITR 337 held that" the language of Section 68 shows that it is general in nature and applies to all credit entries in whomsoever name they may stand." Also, the Hon'ble MP in the case of CIT vs. Shiv Shakti Timbers [1997] 90 taxman 349 held that "a close reading of Section 68 & 69 makes it clear that in the case of Section 68 there should be a credit entr…

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed

ITA 754/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh12 Jan 2024AY 2019-20

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 133Section 133ASection 143(3)Section 14jSection 68Section 69

…ble to the case of the assessee as the credit is there in the capital account of the proprietor and the assessee has no justification to explain its source or nature. The Hon'ble High Court of Punjab & Haryana in the case of Gumani Ram Siri Ram vs. CIT [1975] 98 ITR 337 held that" the language of Section 68 shows that it is general in nature and applies to all credit entries in whomsoever name they may stand." Also, the Hon'ble MP in the case of CIT vs. Shiv Shakti Timbers [1997] 90 taxman 349 held that "a close reading of Section 68 & 69 makes it clear that in the case of Section 68 there should be a credit entr…

M/S MORANI CARS PVT. LTD.,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, WARD-6, JAIPUR

In the result the appeal of the assessee is partly allowed

ITA 184/JPR/2019[2011-12]Status: DisposedITAT Jaipur26 Jul 2022AY 2011-12
For Appellant: Sh. Suhani Maharwal (CA)For Respondent: Sh. A. S. Nehara (Addl.CIT)
Section 139(1)Section 143(3)Section 148Section 40ASection 40aSection 68

…rough cheque but it is liability of the assessee to prove the three limbs within meaning of section 68 of the Act of all the credit entries fund in books of assessee. The Hon’ble High Court Punjab and Haryana in the case of Gumani Ram Siri Ram vs. CIT [ 1975] 98 ITR 337 held as under:- "68. Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof, or the explanation offered by him is not, in the opinion of the Income-tax Officer, satisfactory, the sum so credited may be charged to income-tax as the inco…

SURYA PRABHA SUNKAVALLI,HYDERABAD vs. INCOME TAX OFFICER, WARD-14(3), HYDERABAD

In the result, appeal of the assessee is dismissed

ITA 1327/HYD/2018[2014-15]Status: DisposedITAT Hyderabad06 Jul 2022AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri P.Jitendra Kumar, ARFor Respondent: Shri Kumar Aditya, DR
Section 143(3)Section 40Section 68

…Page 3 of 12 8. Ld. CIT(A) considered the Second question of applicability of section 68 of the Act to the case of the assessee, in the light of the decisions reported in V.I.S.P.(P) Limited Vs. CIT (2004) 265 ITR 202 (MP), Gumani Ram Siri Ram Vs. CIT (1975) 98 ITR 337 (P & H) and Suresh Kumar T. Jain Vs . ITO in ITA No. 667/Bang/2009 dated 08/01/2010 and more particularly by reading the provisions under section 68 of the Act, held that there is no distinction between cash credits/loan credits and other credits, including trade credits, amounts credited to the books of account towards advances received from outs…

MANJU SHARMA,NEW DELHI vs. ITO WARD - 45(5), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed

ITA 8275/DEL/2019[2014-15]Status: DisposedITAT Delhi23 Nov 2020AY 2014-15

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: 2014-15 Manju Sharma, Vs Ito, Wz-43B, Meenakshi Garden, Ward-45(5), New Delhi. New Delhi. Pan: Aatps2170A (Appellant) (Respondent) Assessee By : Shri Krishnan Sampath, Advocate Revenue By : Ms Rinku Singh, Sr. Dr Date Of Hearing : 03.11.2020 Date Of Pronouncement : 23.11.2020 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.09.2019 Passed By The Ld. Cit(A)-15, New Delhi, Relating To Assessment Year 2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & Is Proprietor Of M/S Eastern Galaxy Which Is Engaged In The Business Of Export Of Handicrafts & Decorative Items. She Filed Her Return Of Income On 29.11.2014 Declaring Taxable Income Of Rs.47,10,000/-. The Case Of The Assessee Was Selected For Limited Scrutiny Under Cass With The Reason That There Is “Large Increase In Sundry Creditors With Respect To Turnover As Compared To Preceding Year.”

For Appellant: Shri Krishnan Sampath, AdvocateFor Respondent: Ms Rinku Singh, Sr. DR
Section 131Section 142(1)Section 144ASection 68

…rati (P) Ltd. vs. CIT (1978) 111 ITR 951 (Cal); iii) Prakash Textile Agency vs. CIT (1980) 121 ITR 890 (Cal) 8 iv) CIT v. K.M. Mahim (1995) 81 Taxman 222 (Ker.); v) CIT vs. Precision Finance (P) Ltd. (1994) 208 ITR 465; vi) Gumani Ram Siri Ram vs. CIT (1975) 98 ITR 337 (P&H); vii) Roshan Di Hatti (1977) 107 ITR 938 (SC); viii) Aravali Trading Co. vs. ITO (2010) 187 Taxman 338 (Raj); ix) CIT vs. Mihir Kanti Hazra (2015) 61 taxmann.com 315 (Cal); x) Pr. CIT-7, Delhi vs. Bikram Singh (2017) 85 taxmann.com 104 (Del); xi) Papneja Traders vs. CIT (2012) 20 taxmann.com 752 (P&H); xii) T.P. Abdulla vs. ACIT, Central Cir…

ITO, NEW DELHI vs. M/S. PRIMELAND REAL ESTATES PVT. LTD, NEW DELHI

The appeal of the revenue is dismissed

ITA 1365/DEL/2009[2005-06]Status: DisposedITAT Delhi10 Jan 2020AY 2005-06

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishiasstt. Year: 2005-06

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Ms. Nidhi Srivastava, CIT(DR)
Section 143(3)Section 68

…and it has been held that for justifying any credits in books of account, the assessee must prove identity, capacity of the creditors and genuineness of creditors. In this context the decision reported in 131 Taxman 391 (2003), 49 ITR 112 (SC), 50 ITR 1 (SC), 98 ITR 337 (SC), 161 Taxman 169 (SC), 53 ITR 623 (SC) and 34 ITR 807 (SC) are relied upon and the ratio of judgements in those cases are applicable to the facts of the case under assessment. Under the circumstances these 4 credits amounting to Rs.38,31,03,071/- found unexplained and treated as undisclosed income of the assessee company for the year under con…

THE ACIT, ERNAKULAM vs. M/S. THOMSON METALS, TRICHUR

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 124/COCH/2017[2011-12]Status: DisposedITAT Cochin01 Apr 2019AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Smt.A.S.Bindhu, Sr.DRFor Respondent: Sri. Sathish John Kanichai, FCA
Section 132Section 153CSection 68

…very ITA No.124/Coch/2017. 7 M/s.Thomson Metals. logic of section 68 which is to tax bogus credits in the hands of the assessee who records such credits in the books. 3.b. The CIT(A) erred in not considering the decision in Gumani Ram Siri Ram Vs CIT[1975] 98 ITR 337 (P&H) where it was held that provisions of Section 68 applies to all credit entries. 3.c. The CIT(A) erred in not considering the decision in CIT Vs Kishorilal Santhoshilal (1995) 216 ITR 9 (Raj). 4. The CIT(A) erred in holding that when capital is contributed from unproved sources, the same cannot be assessed as income. The CIT(A) has overlooke…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. AGRASEN AGRO INDUSTRIES PRIVATE LIMITED,, KOTA

ITA 1205/JPR/2018[2011-12]Status: DisposedITAT Jaipur27 Mar 2019AY 2011-12
Section 143(3)Section 153Section 153ASection 68

…ness of the decision of the Tribunal on grounds which might have taken in an appeal against the judgment of the High Court”. Thus, the facts and law of the aforesaid case has no relevancy to that of the case of the Appellant. (vi) G.R. Siri Ram V. CIT (1975) 98 ITR 337 (P&H): The case is also not relevant to the case of Appellant inasmuch as in this case the Appellant had agreed before the ITO that there was no evidence available with the Ladies in support of the cash credits mentioned above. The case of Appellant is not relevant to the facts, mentioned above. In the instant case of Appellant-Company furnished a…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S RAJASTHAN CABLE INDUSTRIES LIMITED, KOTA

ITA 1189/JPR/2018[2016-17]Status: DisposedITAT Jaipur27 Mar 2019AY 2016-17
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 153ASection 68

…made out by the Ld. AO. 20. The ld AR also distinguished the facts laid down in the case of A. Govindarajulu Mudaliar Vs CIT (1958) 34 ITR 807 (SC), G.R. Siri Ram Vs ITA 1121, 1189 & 1052/JP/2018_ 21 M/s Rajasthan Cable Industries Ltd. Vs DCIT CIT (1975) 98 ITR 337 (P&H), CIT Vs. Kishore Lal & Santoshi Lal (1995) 216 ITR 9 (Raj). The detailed submissions filed in this regard is placed on record. 21. With regard to various documentary evidences placed on record, the ld AR has relied on the decision of the Coordinate Bench in the case of M/s Kota Dall Mill A.Y 2010-11, AY 2011-12, AY 2012-13, AY 2013-14,…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA vs. M/S. AGRASEN AGRO INDUSTRIES PRIVATE LIMITED,, KOTA

ITA 1188/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…ness of the decision of the Tribunal on grounds which might have taken in an appeal against the judgment of the High Court”. Thus, the facts and law of the aforesaid case has no relevancy to that of the case of the Appellant. (vi) G.R. Siri Ram V. CIT (1975) 98 ITR 337 (P&H): The case is also not relevant to the case of Appellant inasmuch as in this case the Appellant had agreed before the ITO that there was no evidence available with the Ladies in support of the cash credits mentioned above. The case of Appellant is not relevant to the facts, mentioned above. In the instant case of Appellant-Company furnished a…

M/S RAJASTHAN CABLE INDUSTRIES LIMITED,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

ITA 1121/JPR/2018[2015-16]Status: DisposedITAT Jaipur27 Mar 2019AY 2015-16
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 153ASection 68

…made out by the Ld. AO. 20. The ld AR also distinguished the facts laid down in the case of A. Govindarajulu Mudaliar Vs CIT (1958) 34 ITR 807 (SC), G.R. Siri Ram Vs ITA 1121, 1189 & 1052/JP/2018_ 21 M/s Rajasthan Cable Industries Ltd. Vs DCIT CIT (1975) 98 ITR 337 (P&H), CIT Vs. Kishore Lal & Santoshi Lal (1995) 216 ITR 9 (Raj). The detailed submissions filed in this regard is placed on record. 21. With regard to various documentary evidences placed on record, the ld AR has relied on the decision of the Coordinate Bench in the case of M/s Kota Dall Mill A.Y 2010-11, AY 2011-12, AY 2012-13, AY 2013-14,…

M/S. AGRASEN AGRO INDUSTRIES PRIVATE LIMITED,,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

ITA 1053/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…ness of the decision of the Tribunal on grounds which might have taken in an appeal against the judgment of the High Court”. Thus, the facts and law of the aforesaid case has no relevancy to that of the case of the Appellant. (vi) G.R. Siri Ram V. CIT (1975) 98 ITR 337 (P&H): The case is also not relevant to the case of Appellant inasmuch as in this case the Appellant had agreed before the ITO that there was no evidence available with the Ladies in support of the cash credits mentioned above. The case of Appellant is not relevant to the facts, mentioned above. In the instant case of Appellant-Company furnished a…

M/S RAJASTHAN CABLE INDUSTRIES LIMITED,KOTA vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, KOTA

ITA 1052/JPR/2018[2016-17]Status: DisposedITAT Jaipur27 Mar 2019AY 2016-17
For Appellant: Shri Vijay Goyal (CA) &For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 153ASection 68

…made out by the Ld. AO. 20. The ld AR also distinguished the facts laid down in the case of A. Govindarajulu Mudaliar Vs CIT (1958) 34 ITR 807 (SC), G.R. Siri Ram Vs ITA 1121, 1189 & 1052/JP/2018_ 21 M/s Rajasthan Cable Industries Ltd. Vs DCIT CIT (1975) 98 ITR 337 (P&H), CIT Vs. Kishore Lal & Santoshi Lal (1995) 216 ITR 9 (Raj). The detailed submissions filed in this regard is placed on record. 21. With regard to various documentary evidences placed on record, the ld AR has relied on the decision of the Coordinate Bench in the case of M/s Kota Dall Mill A.Y 2010-11, AY 2011-12, AY 2012-13, AY 2013-14,…

INCOME TAX OFFICER, LUDHIANA vs. SH SURENDER KUMAR PROP, LUDHIANA

The appeal of the Assessee is partly allowed for statistical purposes

ITA 747/CHANDI/2016[2011-12]Status: DisposedITAT Chandigarh08 Feb 2019AY 2011-12

Bench: Itat Shall Not Be Filed In Cases Where The Tax Effect Does Not Exceed The Monetary Limit Of Rs. 20 Lacs. The Tax Will Not Include Any Interest Thereon. It Is Further Clarified That If In The Case Of An Assessee, Disputed Issues Arise In More Than One Assessment Year, Appeal Can Be Filed In Respect Of Such Assessment Year Or Years In Which The Tax Effect In Respect Of Disputed Issues Exceeds The Monetary Limit So Specified.

For Appellant: NoneFor Respondent: Shri Manjit Singh

…n'ble Courts which were produced by the assessee, the Assessing Officer placed reliance on some judgments i.e the Hon'ble Delhi High Court in CIT Vs. Nipun Builders P. Ltd.(350 ITR 407), the Hon'ble P&H High Court in the case of Gurmani Ram Siri Ram vs. CIT (98 ITR 337) and in the case of CIT vs. MAF Academy Pvt. Ltd. ITA No.341/2012, in which the Hon'ble Courts have held that mere furnishing of PAN and confirmation is not enough and the onus to establish the identity, capacity and creditworthiness is upon the assessee. It was held that just because the transaction has been routed through banking channels, it do…

SURINDER KUMAR,LUDHIANA vs. DCIT, LUDHIANA

The appeal of the Assessee is partly allowed for statistical purposes

ITA 475/CHANDI/2016[2011-12]Status: DisposedITAT Chandigarh08 Feb 2019AY 2011-12

Bench: Itat Shall Not Be Filed In Cases Where The Tax Effect Does Not Exceed The Monetary Limit Of Rs. 20 Lacs. The Tax Will Not Include Any Interest Thereon. It Is Further Clarified That If In The Case Of An Assessee, Disputed Issues Arise In More Than One Assessment Year, Appeal Can Be Filed In Respect Of Such Assessment Year Or Years In Which The Tax Effect In Respect Of Disputed Issues Exceeds The Monetary Limit So Specified.

For Appellant: NoneFor Respondent: Shri Manjit Singh

…n'ble Courts which were produced by the assessee, the Assessing Officer placed reliance on some judgments i.e the Hon'ble Delhi High Court in CIT Vs. Nipun Builders P. Ltd.(350 ITR 407), the Hon'ble P&H High Court in the case of Gurmani Ram Siri Ram vs. CIT (98 ITR 337) and in the case of CIT vs. MAF Academy Pvt. Ltd. ITA No.341/2012, in which the Hon'ble Courts have held that mere furnishing of PAN and confirmation is not enough and the onus to establish the identity, capacity and creditworthiness is upon the assessee. It was held that just because the transaction has been routed through banking channels, it do…

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