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Corporate TaxArticle·21 March 2026

Mistaken Identity and Section 68

By J the App

Executive Summary

This case addresses a common issue in reassessment proceedings, additions based on alleged accommodation entries. 

The Tribunal held that merely relying on third-party confirmation without establishing a clear nexus with the assessee is insufficient. 

Where the assessee demonstrates, through bank records and evidence, that no such transaction occurred, the burden shifts back to the Revenue. 

In the absence of such proof, the addition under Section 68 cannot survive. The appeal was allowed in favour of the assessee.


The present order dated 9th February 2026 was passed by the Income Tax Appellate Tribunal, Mumbai Bench, in the case of Blue Chip Financial Services Private L...

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