ACIT CIRCLE-1(1), RAJKOT, RAJKOT vs. JYOTI CNC AUTOMATION LIMITED, RAJKOT

ITA 224/RJT/2026Status: DisposedITAT Rajkot14 September 2026AY 2020-2127 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the deletion of additions made on account of unexplained cash credits and expenditure. The Assessing Officer treated a loan of Rs. 76,57,520/- as unexplained cash credit and the interest thereon as unexplained expenditure, based on information from an investigation wing regarding accommodation entries.

What did the Tribunal hold?

The Tribunal held that the assessee had discharged its primary onus by providing documentary evidence of transactions through banking channels, including ledger accounts and bank statements. The Tribunal also noted that TDS was deducted on interest paid and the loan was repaid.

What were the issues?

Whether the CIT(A) erred in deleting additions related to unexplained cash credits and expenditure when transactions were conducted through banking channels. Whether the assessee is entitled to deduction under Section 35(2AB) despite the prescribed authority not submitting Form 3CL.

Which sections of the Income-tax Act were involved?

Section 68,Section 69C,Section 115BBE,Section 35(2AB)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Biren Shah, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. CIT DR and Ganesh Iyer, Ld. Sr. DR
Hearing: 13/08/2026

Per, Dr. Arjun Lal Saini, AM: Captioned three appeals filed by the Revenue, pertaining to assessment years (AYs) 2019-20, 2020-21 & 2022-23, are directed against the separate orders, under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the National Faceless Appeal Centre (NAC)

Delhi/Commissioner of Income-tax (Appeals) [in short ‘NFAC/Ld.CI

The order continues below.

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