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The appellant has not been able to discharge the initial onus which lay on it as per section 68 respect to the security deposits aggregating Rs. 2,44,40,054/- to and the ratios of the judicial decisions relied upon by it do not apply to its case. Hence, the action of the Assessing Officer in adding these amounts to the appellant's income u/s 68 is confirmed.

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Sec. 68 of Income Tax Act, 1961—Cash Credit — The three necessary ingredients of section 68 have not been established by the assessee, who cannot simply get away by stating that the deposits shown under the head 'unclaimed receipts' were ultimately reconciled and the parties from whom they were received were identified, the onus was on the assessee to establish the identities and creditworthiness of these parties as also the genuineness of the transactions which it failed to do both at the assessment and appellate stage, accordingly, the impugned addition to income made by the Assessing Officer is upheld — Carol securities pvt. ltd. vs. DEPUTY CIT [2020] 78 ITR (TRIB) 469 (ITAT-DELHI)

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