Dismissing the appeal of the revenue the Court held that ; the assessee is not required to explain the “source of source” prior to insertion of the proviso to S. 68. If the assessee has discharged the primary onus placed upon it u/s 68 by filing confirmation letters, the Affidavits, the full address and pan numbers of the creditors, the Revenue has to proceed against the persons whose source of funds are alleged to be not genuine . There was no obligation to explain the source of source prior to April 1 2013 , assessment year 2013-14 ( ITA No. 819 of 2015, dt. 17.04.2018)( AY. 2010-11)
PCIT v. Veedhata Tower Pvt. Ltd.(2018) 403 ITR 415/ 166 DTR 218 / 302 CTR 490 (Bom)(HC) , www.itatonline.org
S. 68: Cash credits –Not required to explain source of source -Confirmation letters , affidavits PAN no was filed, deletion of addition was held to be justified .
kindly send the full judgement orderin case of PCIT v. Veedhata Tower Pvt. Ltd. (2018) 403 ITR 415/166 DTR 218/ 302 CTR 490 (Bom)(HC)