Bench: Shri Kul Bharat & Shri Manish Borad
195 and Mod Creations (P) ltd (2013) 354 ITR 282 (Del). Since appellant discharged initial onus, the onus shifted on revenue and there was no legal obligation on the appellant to produce directors of creditors before AO and if AO had any doubt about identity of share applicants despite their filing income tax returns, he could have summoned them