Section 68 Cannot rest on Procedural Gaps

In a multi-issue dispute involving unexplained credits, loans, and expenses, the Tribunal held that once the assessee discharges the primary onus under Section 68 through documentary evidence and transactional substantiation, additions cannot be sustained in the absence of independent enquiry by the tax authorities. 

The ruling also clarifies that technical defects in documentation or minor inconsistencies such as address mismatches do not override substantive commercial realities.