While making an addition under s 68, the AO has to advert to each and every entry and not pick up a couple of entries, as in the present case, and label the entire set of deposits made during the assessment year as undisclosed income of the assessee, as held by DelHC in CIT v Kinetic Capital Finance Ltd — In favour of: The assessee.
Once the assessee has discharged that initial onus, he is not required thereafter to prove the genuineness of the transactions as between its creditors and that of the creditors’ source of income, ie the sub-creditors.
Decided on: 2 September 2011.
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