Dismissing the appeal of the revenue the Court held that, merely because the investment was considerably large and several corporate structures were either created or came into play in routing the investment in the assessee through a Mauritius entity would not be sufficient to brand the transaction as colourable device. The assessee cannot be asked to prove the source of source. (PCIT v. NRA Iron & Steel (2019) 103 taxmann.com 48 (SC) is referred) (ITA No. 1502 of 2016, dt. 26.03.2019) (AY. 2009 -10 )
PCIT v. Aditya Birla Telecom Ltd( 2019) 178 DTR 418/ 263 Taxman 539 (Bom.)(HC), www.itatonline.org, Editorial : SLP of revenue dismissed , PCIT v. Aditya Birla Telecom Ltd ( 2021 ) 278 Taxman 8 (SC)
S. 68 : Cash credits-Bogus Share Capital-Merely because the investment was considerably large and several corporate structures were either created or came into play in routing the investment in the assessee through a Mauritius entity would not be sufficient to brand the transaction as colourable device-The assessee cannot be asked to prove the source of source.