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Corporate TaxArticle·7 April 2026

Share Capital Scrutiny Section 68

By J the App

Executive Summary

In a significant reaffirmation of Section 68 jurisprudence, the Delhi ITAT has held that once an assessee establishes identity, creditworthiness, and genuineness through documentary evidence, supported by independent verification, the burden shifts decisively to the Revenue. 

Mere reliance on investigation wing reports or alleged accommodation entry networks, without specific linkage or money trail, is insufficient to sustain additions. 

The ruling reinforces evidentiary discipline in share capital cases and curtails mechanical application of suspicion-driven assessments.



Issues for Determination

The Tribunal was called upon to determine whether share capital received from an alleged...

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