The assessee claimed that the cash expenditure incurred for production of a film was on behalf of the production house and that she was merely a “pass-through entity”. The Tribunal held that the cash expenditure was not recorded in the books, the assessee failed to produce the production house or establish the source of the cash payments and could not shift the burden after expiry of the limitation period. The additions under sections 69C and 69A were therefore upheld. (AY. 2012-13 to 2014-15).