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It is well settled that in view of Section 68 of the Act, where any sum is found credited in the books of the assessee for any previous year, the same may be charged to income tax as the income of the assessee of that previous year, if the explanation offered by the assessee about the nature and source thereof is, in the opinion of the assessing officer, not satisfactory. 

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Section 68 of the Income Tax Act, 1961 — Cash Credit —The law is well settled that the onus of proving the source of a sum of money found to have been received by the assessee is on him and if he disputes his liability to tax, it is for him to show that the receipt is not income it is exempted from tax and in the absence of such proof, the Department is entitled to treat it as taxable income. Additions of sums as income from undisclosed sources was valid as assessee claimed that sums were received as loan and onus was on the assessee to establish creditworthiness and genuineness of creditor and the onus was not discharged by assessee— Sajid Khan vs. Principal Commissioner of Income tax [2019] 417 ITR 1 (Allahabad)

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