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In favour of assessee. The burden of proving the source of the credits having been sufficiently explained the addition could not have been made in the hands of the firm in the facts of the presentcase.

Shanti Prime Publication Pvt. Ltd.

Sec. 68 of Income Tax Act, 1961—cash credit - The partners have shown the agricultural income in their personal returns of the past years which had been accepted by the department as such. The partners are all identifiable and separately assessed to tax. The source of investment having been explained, in the event the AO was not satisfied the addition could have been considered in the hands of the partners and not in the hands of the firm. The burden of proving the source of the credits having been sufficiently explained the addition could not have been made in the hands of the firm. Appeal of the assessee allowed. - KESHARWANI SHEETALAYA SAHSAON ALLAHABAD V/s CIT - [2020] 315 CTR 815 (ALL)