INCOME TAX OFFICER-1, MORENA vs. SHRI AGRASEN LOGISTICS, JOTAI ROAD, PORSA,

In the result, the appeal of the Revenue is dismissed

Section 68. Those are: (i)identity of the investors; (ii) their\ncreditworthiness; and (iii) genuineness of the transaction. The department's exercise starts\nonly when these three ingredients are established prima facie, by the assessee.\n12. The Hon'ble Calcutta High Court) in Shankar Industries v. CIT [1978] 114 ITR 689 has\nheld that the Assessee must prove identities