ACIT CIRCLE 1 1, RAJKOT vs. TANVI EXPORT INDIA LIMITED, RAJKOT

ITA 681/RJT/2025Status: DisposedITAT Rajkot11 September 2026AY 2023-244 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the assessee failed to provide evidence for the 'source of the source' as required by the first proviso to Section 68. Therefore, the matter was remitted back to the Assessing Officer for fresh adjudication.

What were the facts?

The Revenue appealed an order concerning AY 2023-24 regarding unsecured loans. The assessee had provided evidence for the source of the loan but not the 'source of the source'. The assessee requested more time to provide this evidence but was denied by the CIT(A).

What were the issues?

Whether the assessee adequately explained the 'source of the source' for unsecured loans as mandated by Section 68, and if not, whether an opportunity should be granted to provide such evidence.

Which sections of the Income-tax Act were involved?

Section 68,Section 143(3),Section 144B

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 Hiren Trivedi, Ld. AR
For Respondent: Shri Ravinder Sindhu, Ld. CIT DR
Hearing: 12/08/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the Revenue, pertaining to assessment year (AY) 2023-24, is directed against the order 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.CIT(A)’], dated 28.08.2025, which in turn arises out of an assessment order

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 68

All 29,931 judgments and leading authorities on Section 68 →

Recent GST High Court judgments

Search GST case law →