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enquiry under s. 68 of the Act, the assessee had furnished the respective balance sheets of the applicants for shares in the assessee, the identity and creditworthiness of such applicants for shares ought to be deemed to have been established. In the present case, the balance sheets or the accounts of the applicants for shares were not furnished by the assessee. On the contrary, the assessee purported to rely on similarly-worded affidavits apparently produced from the persons whose existence was doubted at every stage by the authorities. It is curious that 21 share applicants would write identical letters to the two proprietorship concerns of the principal person in control of the assessee and his wife on the same date and such persons would require the amounts standing to their credit in the proprietorship concern to be made over as share application money to the assessee-company and all such 21 applicants would leave Calcutta within a few years of applying for such shares. The authorities below drew the appropriate conclusions from the facts as evident therefrom.

Shanti Prime Publication Pvt. Ltd.

Sec. 68 of Income-tax Act, 1961— Income—DRB EXPORTS P. LTD. vs. CIT.[2018] 305 CTR 95 (CAL)

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