The primary onus to demonstrate the nature and source of the credit is on the assessee. Only when such onus is discharged by the assessee, does it shift to the department. Where the assessee only filed a list of investors, which did not even contain their PAN numbers, it could not be said that the assessee had discharged its onus. (AY. 2006-07)
PCIT v. SRM Systems And Software P. Ltd. (2021) 433 ITR 111 (Mad.) (HC)
S. 68 : Cash credits-Share application money-Primary onus on the assessee-Identity was applicants not established-Addition is held to be justified.