Source of source in respect of loans not required to be proved under section 68 of the ITA as it stood prior to 01.04.2023
Section 68 of the ITA (as it stood prior to 01.04.2023) did not required the taxpayer to explain the source of the source of funds for sum credited to its books other than share capital money, share capital, share premium or any amount of such nature.
The expression โany such amountโ, appearing in the proviso, would take its colour from the terms share application money, share capital and share premium, and, therefore, would not cover loan or borrowing or any such amount within its ambit.
๐ฆ๐ต๐ฒ๐ฒ๐น๐ฎย ๐ข๐๐ฒ๐ฟ๐๐ฒ๐ฎ๐ย ๐ฃ๐ฟ๐ถ๐๐ฎ๐๐ฒย ๐๐ถ๐บ๐ถ๐๐ฒ๐ฑย ๐.ย ๐ฃ๐๐๐งย [๐๐ง๐ย ๐ฑ๐ฐ๐ฒ/๐ฎ๐ฌ๐ฎ๐ฏ],ย ๐ฑ๐ฎ๐๐ฒ๐ฑย ๐ฎ๐ด.๐ฌ๐ฑ.๐ฎ๐ฌ๐ฎ๐ฑย [๐๐ฒ๐น๐ต๐ถย ๐๐ถ๐ด๐ตย ๐๐ผ๐๐ฟ๐]
ย
The copy of the order is as under:
