In the result, the departmental appeal is dismissed
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
68 has to be understood as a requirement of identification of source and its genuineness. It is also a settled legal position that the onus of the assessee, of explaining nature and source of credit, does not get discharged merely by filing confirmatory letters, or demonstrating that the transactions are done through the banking channels or even by filing