GXP PHARMACEUTICALS PRIVATE LIMITED,PUNE vs. ACIT, CIR-1(2), PUNE, PUNE

PDF · subscribers
ITA 862/PUN/2025Status: DisposedITAT Pune25 June 2026AY 2016-1721 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had discharged its onus by providing sufficient material to establish the identity, creditworthiness of the source, and genuineness of the transaction. Therefore, the addition made by the Assessing Officer was deleted.

What were the facts?

The assessee company received an unsecured loan of Rs. 1,00,00,000/- from its promoter director. The Assessing Officer added this amount to the assessee's income under Section 68, holding that the assessee failed to prove the creditworthiness of the lender and the genuineness of the transaction.

What were the issues?

Whether the assessee had adequately proved the identity, creditworthiness, and genuineness of an unsecured loan received from its promoter director to avoid addition under Section 68.

Which sections of the Income-tax Act were involved?

Section 68,Section 115JB,Section 115BBE,Section 143(2),Section 142(1),Section 250,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI RAMA KANTA PANDA & Ms. ASTHA CHANDRA

For Appellant: Shri Rajendra Agiwal
For Respondent: Shri Madhan Thirmanpalli, Addl.CIT

PER ASTHA CHANDRA, J.M.:

The appeal filed by the assessee is directed against the order dated 24-01-2025 of the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi [“CIT(A)/NFAC”] u/s. 250 of the Income Tax Act, 1961 (the “Act”), pertaining to Assessment Year (“AY”) 2016-17. 2. Briefly stated, the facts of the case are that the assessee is a private Limited company and engaged in the provision of business support services to its group companies. For AY 2016-17, the assessee filed its return of income on 29-11-2016, declaring total income of Rs. Nil. Since the assessee had inadvertently not considered unabsorbed loss/depreciation as per books of account while calculating the Minimum Alternate Tax (MAT) liability in its original return of income, revised return was filed on 25.10.2017 declaring total income of Rs. Nil. The case of the assessee was selected for limited scrutiny under CASS. Accordingly,

2 statutory notices u/s. 143(2) and 142(1) of the Act alongwith questionnaire were issued and served upon the assessee, calling for information/documentary evidences in relation to the issues identified for limited scrutiny in response to which, the assessee duly furnished the requisite details/documentary evidences. It was found that during the relevant AY 2016-17, the assessee had availed unsecured loan amounting to Rs. 1,00,00,000/- from the Promoter Director, Mr. Sanjiv Puri. During the course of assessment proceedings, the Ld. Assessing Officer (“AO”) asked the assessee to prove the identity, creditworthiness of the lender and genuineness of the aforesaid transaction by submitting the confirmation from the lender, his return of income and bank statements. The assessee submitted copy of PAN, bank details, Form-16 and loan confirmation letter in order to establish the identity and creditworthiness of the creditor (lender) and genuineness of the transaction. But return of income of the lender could not be submitted since due to his non-resident status, the lender did not file his return of income for AY 2016-17. However, rejecting the submissions of the assessee, the Ld.AO proceeded to complete the assessment by determining the total income of the assessee at Rs. 1,00,00,000/- as per the normal provisions of the Act and Rs. 1,50,26,163/- assessed as per book profits u/s. 115JB of the Act, thereby making an addition of the said impugned amount of Rs. 1,00,00,000/- as unexplained credits u/s. 68 of the Act, vide his order passed u/s. 143(3) of the Act, dt. 29-11-2018, by observing as under:

“3. 9. The submission of the assessee has been carefully examined and considered. Through this submission also, the assessee has not furnished the Income Tax returns of the creditor though it has been submitted again and again that the creditor was a promoter director of the assessee company. Hence, the creditor is a closely related person and the onus is heavier on the assessee to prove the credits. The assessee's contention that the creditor Mr. Sanjiv Puri had substantial earning from salary and the amount was advanced through banking channel is not acceptable for the reasons that the bank statement of the creditor shows that the payment of Rs. 1,00,00,000/- was made on 03.06.2015 and there were two deposits of Rs. 50,00,000/- each on 23.05.2015. Prior to this date, the available balance in the account of the creditor was only Rs. 5,50,881/-. Hence, the contention of the assessee

3 that the amount was paid out of salary income does not hold good. It is apparent that the amount of Rs. 1,00,00,000/- was transferred out of deposits of Rs. 1,00,00,000/- just before the alleged transfer. The source of these two deposits has to be proved beyond the shadow of reasonable doubt. The contention of the assessee that the payments were made through banking channel hence the transaction is genuine is also not acceptable. The Hon'ble Kerala High Court in the case of ITO Vs Diza Holdings (P) Ltd. [2002] 120 Taxman 539 held that "it is clear in terms of section 68 that the burden is on the assessee to offer a satisfactory explanation about the nature and source of the amount found credited in the books of the assessee. It is also clear that mere furnishing of particulars is not enough. The mere fact that payment was made by way of account payee cheque is also not conclusive, Therefore, the AO would be entitled to consider whether notwithstanding the fact that the payments were made by cheques, whether the assessee has satisfactorily explained the nature and source of the amounts found credited in the books of the assessee.

3.

10 In view of the above facts and discussion, it is clear that the assessee failed to prove the creditworthiness of the creditor and genuineness of the transaction. As the copies of income tax returns of the creditor have not been furnished either by the assessee or by the creditor himself, needless to say that he is the promoter director of the assessee company, the creditworthiness is not proved. The bank statement also does not show the sufficient balance out of salary income as discussed above. As regards, the genuineness of transaction, this aspect is also not proved by the assessee as the two deposits of Rs. 50,00,000/- each immediately prior to the transfer of amount, source of which has not been explained, makes the transaction doubtful. It is also the responsibility of the creditor who is himself the promoter director of the assessee company to co-operate in the assessment proceedings but he remained unresponsive. It appears that he is not filing his returns of income thereby disclosing the taxable income and in the absence of the same, the amount transferred from his bank account cannot be held as made out of disclosed sources. Hence, the source of the money so credited in the books of the assessee remains unexplained.

3.

11 It is, therefore, held that the assessee failed to prove the credits and the unexplained credits of Rs. 1,00,00,000/- represents assessee's undisclosed income brought in the books of accounts in the guise of unsecured loan. Hence, Rs. 1,00,00,000/- is treated as deemed income of the assessee within the meaning of section 68 of the Income Tax Act and is charged to tax u/s 115BBE of the Income Tax Act' 1961. Accordingly, this amount is added to the total income.”

3.

Aggrieved, the assessee challenged the above addition made by the Ld.AO. Before the Ld. CIT(A)/NFAC, the assessee reiterated all the submissions which were earlier made before the Ld.AO. However, rejecting the same and placing reliance on catena of decisions dealing with addition under section 68 of the Act, the Ld.CIT(A)/NFAC dismissed the assessee‟s grounds on the impugned issue and confirmed the addition made by the Ld.AO. The relevant extract of the findings and observation of the Ld. CIT(A)/NFAC is reproduced below:

4 “4. The grounds of appeal no. 1 to 6 are interlinked, hence dealt together, are against the action of the AO in making addition of Rs.1,00,00,000/- on account of unexplained cash credit u/s.68 of the I.T. Act, 1961. 4.1 I have considered the facts of the case/reassessment order. The facts of the case, as perused from the order of the AO are that the assessee had filed return of income on 29.11.2016 declaring total income of Rs. Nil. Subsequently, the assessee revised the return of income and filed a revised return on 25.10.2017 declaring total income at Rs. Nil. The case was selected for scrutiny under CASS and accordingly, notice u/s.143(2) of the Act was issued on 18.09.2017. During the course of assessment proceedings, the AO had noticed that the assessee had received unsecured loan amounting to Rs.1,00,00,000/- from Shri Sanjiv Puri during the year under consideration. During the course of assessment proceedings, the assessee was asked vide letter dated 01.06.2018 to furnish the details of the amounts so credited and confirmation from the creditor, his IT returns and bank statements to prove the identity, creditworthiness and genuineness of the transactions within the meaning of section 68 of the Income Tax Act. However, the assessee has only furnished copies of PAN card and a confirmatory letter from Mr. Sanjiv Puri but not furnished copy of IT return and bank statement. Thereafter, the AO had issued show cause letter dated 13.07.2018 by which the assessee's attention was invited towards its failure to prove the credits within the meaning of section 68 of the Income Tax Act 1961. The compliance was required to be made on 20.07.2018, but no compliance was made by the assessee. Therefore, again, the AO vide letter dated 31.07.2018, reminded the assessee to file the requisite documents and explanation as to why the credits of Rs.1,00,00,000/- should not be treated as its deemed income. However, the assessee has again failed to furnish the necessary details as called for by the AO but filed a reply, which was considered by the AO. After consideration of the reply filed by the assessee, the AO found that in addition to the confirmatory letter, the assessee furnished copy of Form 16 in support of salary paid to the creditor and bank statement of the creditor. But, the assessee had not furnished copies of the income tax returns filed by the creditor to prove the creditworthiness of the creditor. On verification of the same, it has been found that the lender Shri Sanjiv Puri was paid salary by the assessee company during the previous year amounting to Rs.1,71,00,000/- on which tax was also deducted. But, this was not sufficient to prove that the money so advanced to the assessee was out of such salary payment. The bank statement of Shri Sanjiv Puri also reveals that before advancing the amount of Rs.1,00,00,000/- to the assessee there were two deposits of Rs.50,00,000/- each in his bank account which was not part of the salary payment. Prior to this there was no sufficient balance in his account to advance such money to the assessee, which made the transaction doubtful. 4.1.1 Further, in the meantime, on the basis of addresses available as per Form No. 16A, bank statement and other documents pertaining to the creditor, a notice-u/s.133(6) of the I.T. Act has been issued on 10.09.2018 to Shri Sanjiv Puri on the said three addresses by registered post and also on his e-mail account as available in his bank statement of Yes Bank Ltd. by the AO, requiring him to confirm in writing the said transaction, to furnish his income tax returns for A.Y.2014-15, 2015-16 & 2016-17, copy of his bank statements through which the said money was advanced and also to prove the source of deposits of Rs.1,00,00,000/- prior to advancing the money to the assessee. However, one letter returned un served by the postal authorities with a remark "Left". In respect of another letter, a reply has been received from Shri Harish Lakhani that Shri Sanjiv Puri was his Licensee of the flat and vacated the flat prematurely. The third letter addressed to 1203, Royal Grandeyr Aundh Road, Pune seems to be served on him as it has notbeen returned by the postal authorities. But, no reply has been received from Shri Sanjiv Puri against this served letter or in response to the e-mail sent on his e-mail ID. In view of these facts, the AO had again issued a show cause letter dated 21.09.2018 to the assessee and informing the status of 5 the enquiry made through notice u/s.133(6) of the Act. In response to the said show cause notice, the assessee had filed a reply, which was also considered by the AO. After perusal of the submission, the AO found that through this submission also, the assessee had not furnished the Income Tax returns of the creditor though it had been submitted again and again that the creditor was a promoter director of the assessee company. Hence, the creditor was a closely related person and the onus was heavier on the assessee to prove the credits. The AQ further stated that the assessee's contention that the creditor Shri Sanjiv Puri had substantial earning from salary and the amount was advanced through banking channel was not acceptable for the reasons that the bank statement of the creditor shows that the payment of Rs.1,00,00,000/- was made on 03.06.2015 and there were two deposits of Rs.50,00,000/- each on 23.05.2015. Prior to this date, the available balance in the account of the creditor was only Rs. 5,50,881/-. Hence, the AO held that the contention of the assessee that the amount was paid out of salary income does not hold good. The AO further stated that it is apparent that the amount of Rs.1,00,00,000/- was transferred out of deposits of Rs.1,00,00,000/- just before the alleged transfer and therefore, the source of these two deposits has to be proved beyond the shadow of reasonable doubt. Thus, the AO held that the contention of the assessee that the payments were made through banking channel hence the transaction was genuine is also not acceptable. In support of his finding, the AO had relied on the decision of the Hon'ble Kerala High Court in the case of ITO Vs Diza Holdings (P) Ltd. [2002] 120 Taxman 539, wherein the Hon'ble Court held that "it is clear in terms of section 68 that the burden is on the assessee to offer a satisfactory explanation about the nature and source of the amount found credited in the books of the assessee. It is also clear that mere furnishing of particulars is not enough. The mere fact that payment was made by way of account payee cheque is also not conclusive, Therefore, the AO would be entitled to consider whether notwithstanding the fact that the payments were made by cheques, whether the assessee has satisfactorily explained the nature and source of the amounts found credited in the books of the assessee". 4.1.2 In view of the above facts and discussion, the AO held that that the assessee failed to prove the creditworthiness of the creditor and genuineness of the transaction as the copies of income tax returns of the creditor had not been furnished either by the assessee or by the creditor himself, needless to say that he was the promoter director of the assessee company, the creditworthiness was not proved. The AO also held that the bank statement also did not show the sufficient balance out of salary income as discussed above. As regards, the genuineness of transaction, the AO held that this aspect was also not proved by the assesseeas the two deposits of Rs.50,00,000/- each immediately prior to the transfer of amount, source of which had not been explained, makes the transaction doubtful. The AO has further stated that it was also the responsibility of the creditor who was himself the promoter director of the assessee company to co-operate in the assessment proceedings but he remained un responsive. It appears that he was not filing his returns of income thereby disclosing the taxable income and in the absence of the same, the amount transferred from his bank account cannot be held as made out of disclosed sources. Hence, the AO finaly held that the source of the money so credited in the books of the assessee remains unexplained. Therefore, the AO had made addition of Rs.1,00,00,000/- on account of unexplained credit under section 68 of the Act while passing the assessment order. While making the addition, the AO has also relied on the decision of the Hon'ble Supreme Court in the case of Roshan Di Hatti V CIT [1977] 107 ITR 938, Kalekhan Mohammad Hanif Vs. CIT[1963] 50 ITR 1, wherein the Hon'ble Apex Court held that the law is well settled that the onus of proving the source of a sum of money found to have been received by an assessee, is on him. Where the nature and source of a receipt, whether it be of money or other property. cannot be satisfactorily explained by the assessee, it is open to the revenue to hold that it is the income of the assessee and no further burden lies on the revenue to show that the income is from any particular source. The AO has also relied on the 6 decision of the Hon'ble Calcutta High Court in the case of Shankar Industries Vs. CIT [1978] 114 ITR 689, wherein the Hon'ble High Court held that it is necessary for the assessee to prove prima facie the transaction which results in a cash credit in his books of account. Such proof includes proof of the identity of the creditor, the capacity of such creditor to advance the money and lastly the genuineness of the transaction.

4.

2 During the course of appellate proceedings, the appellant has filed written submissions (reproduced supra) and taken contentions. On perusal of the submission filed by the appellant, it is observed that the appellant has claimed that it has discharged its onus by furnishing the documents as laid down in section 68 of the Act i.e. copy of confirmation letter of lender, copy of PAN Card, copy of bank statement of lender, copy of form 16 issued to the lender. The appellant has also furnished a copy of reply dated 18.10.2018 given by the lender to the AO during the course of assessment proceedings, in which the lender has stated that the aforesaid credit of Rs.50,00,000/- was received by him from a related party as repayment of interest free loan given earlier. The lender had also stated that the said loan was advanced by him from his salary income. Thus, the appellant has requested to delete the addition made.

4.

3 In this background, case of appellant and its facts are discussed herein below.

5.

Discussion about the provisions of section 68 of the Income Tax Act and interpretation about the condition of this section by the Hon'ble Courts: -

5.

1 Before coming to the facts of the case, it is important to understand the provisions given in the Act, its interpretation by judicial authorities and there from deriving the tests for examining the allowability of issue.

5.

2 According to the basic principle of accounting whatever is credited in bank accounts and books of accounts of assessee is an income, unless proved by assessee that same does not form part of its income. As it is for the person whose accounts has been credited to prove that same do not form part of income, it is his duty and onus to prove the opposite. To give the shape to this basic principle of accounting, section 68 of Income Tax Act has been enacted. The provisions of section are reproduced as under: Cash credits.

68.

Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the [Assessing] Officer, satisfactory, the sum so credited may be charged to income-tax as the income of the assessee of that previous year"

5.

3 Above provisions of act, which is intended to follow the above discussed accounting principle, even if read strictly word to word, cast onus on assessee in two folds:

1.

Assessee has to offer an explanation about nature, and source;

2.

Explanation offered by him should be found satisfactory by the Assessing found satisfactory by the Officer.

5.

4 First, let us try to understand the words used in section namely-nature & source. Various judicial authorities from time to time including the Hon'ble Apex Court have tried to interpret these two phrases, and all of the judicial pronouncements have agreed that while explaining the nature & source, assessee has to offer an explanation and prove the credit to the satisfaction of AO basically on three aspects:

1.1.

Identity of his creditors;

2.

Capacity of creditors to advance money; and 7

3.

Genuineness of transaction.

5.

5 It is important to reiterate that these three tests have been finalized and accepted by Hon'ble Apex Court from time to time, even in the decision in case of N. Tarika Property Invest. (P.) Ltd. v. Commissioner of Income-tax [2014] 51 taxmann.com 387 (SC), and even Gujarat High Court in case of UmeshKrishnani vs. ITO (2013) 35 Taxman 598 (Gujarat). Earlier, the Hon'ble Apex Court in the case of CIT Vs P. Mohanakala (2007) 161Taxman 169/291 ITR 278 (SC), while considering the scope of section 68, observed as under:- ".... The expression the assessee offer no explanation means where the assessees offer no proper, reasonable and acceptable explanation as regards the sums found credited in the books maintained by the assessees...."

5.

6 Thus, the assessee not only has to give explanation about nature & source on three basic ingredients, the explanation has to be proper, reasonable & acceptable. While discussing the phrases proper, reasonable &acceptable, Hon'ble Apex Court in case of CIT v. Durga Prasad More [1971] 82 ITR 540 (SC) has pronounced that "Science has not yet invented any instrument to test the reliability of the evidence placed before a Court or Tribunal. Therefore, the Courts and Tribunals have to judge the evidence before them by applying the test of human probabilities". Thus, here, Hon'ble Court has laid down the test of human probability. This test of human probability has again been reiterated by Hon'ble Apex Court in the case of Sumati Dayal v. CIT [1995] 80 Taxman 89/214 ITR 801 (SC), wherein it was specifically pronounced that revenue authorities are supposed to consider the surrounding circumstances and apply human probability.

5.

7 From above discussion, it emanates that assessee has to offer an explanation about nature & source of credit, basically including three ingredients viz. identity of creditors, capacity of creditors to advance money (which is normally referred as creditworthiness) and genuineness of transaction; and such explanation should be proper, reasonable & acceptable, and should pass the test of human probability.

5.

8 The second limb of section casts another onus on assessee is that the explanation should be to the satisfaction of AO. Thus, it is clear, that if AO is not satisfied and asks additional evidences from assessee, the assessee is duty bound to produce further details or persons for verification. The assessee cannot take the plea that he has submitted some papers and his onus has been discharged. If AO tries to probe on his own, and gathers some material, which is sufficient to cast doubt on source & nature of credit, it is the duty of assessee to provide further explanation and material as required by AO. Similarly, if the AO at any stage of probe reaches a dead end, and informs the assessee about the same, it is duty of assessee, to help him in and provide whatever is asked and is in his possession, to resolve that dead end. This position of shifting of onus from assessee to AO & AO to assessee is a tricky one, which depends on the specific facts of any case. In this regard Hon'ble Apex Court in case of CIT v. Durga Prasad More [1971] 82 ITR 540 (SC) has stated: "Now, coming to the question of onus, the law does not prescribe any quantitative test to find out whether the onus in a particular case has been discharged or not. It all depends on the facts and circumstances of each, case. In some cases, the onus may be heavy whereas, in others, it may be nominal. There is nothing rigid about it" ………. ……….

8 5.8.9 In light of above facts, discussions and judicial pronouncement, the tests evolved for testing any credit entry in books of assessee has to be as follows:

1.

Identity of his creditors;

2.

Capacity of creditors to advance money; and 3. Genuineness of transaction. 4.Assessee should offer proper, reasonable and acceptable explanation.

5.

Explanation should stand the test of human probability.

6.

Explanation should be coherent with surrounding circumstances.

7.

In case of private limited companies, onus is higher on assessee, as rightly termed by Hon'ble High Court of Delhi in case of CIT vs. Navodaya Castles P. Ltd 50 Taxman 110 (2014) as Angel Investor.

8.

The Onus of assessee is not over when he gives an explanation. If AO expresses its dis-satisfaction, or asks further details, or asks the assessee to produce the person for his satisfaction, the onus shifts on the assessee again. Similarly, if the AO while carrying probe himself gathers some material and puts the same before the assessee, the onus again shifts on the assessee to prove the same otherwise. Similarly, if the AO reaches a dead end while carrying out his probe and informs the assessee about the same, the assessee is duty bound to help him in resolving the dead end. Thus, onus shifts from assessee to AO, or AO to assessee, can take several rounds depending upon material produced by assessee, gathered by AO, or depth of probe made by AO.

5.9.

The issue of “IDENTITY’. ………. ………. 5.9.5 In light of above judicial pronouncements it become clear that for proving the identity; assessee has to fulfill at least the following details:-

1.

Name, Address, PAN card, assessment details, share application forms.

1.

Place of work of investor, its staff, its actual business, and its recognition in public eye and.

5.

10 The Issue of 'CREDITWORTHINESS': ………. ……….

5.10.

8 Thus judicial pronouncements puts followings test on assessee: -

1.

Whether investor was having sufficient cash resources at its disposal.

2.

Whether investor was having annual income in commensurate to the investment made.

3.

What was the source of money in hands of investors and its genuineness.

4.

Whether the said investment was commercially prudent for investors.

5.

11 Issue of genuineness of transactions: -

9 Genuineness of transaction has basically two limbs, first whether the said transaction has actually happened and testing the facts and reasons given by assessee on the doctrine of "Human Probability, which include commercial prudence, and surrounding circumstances. The judicial pronouncement for Human probability, commercial prudence & surrounding circumstances have already been discussed above.

5.

12 In the light of above discussion, it is very important to consider the result of investigations conducted in this case. On almost all counts mentioned above whether it is identity, genuineness or creditworthiness the assessee has failed to completely discharge its onus.

6.

On perusal of the above legal matrix, it is observed that the Hon'ble Courts/ITAT has held that the assessee has to discharge its onus by furnishing the necessary evidences in respect of identity & creditworthiness of the investors and genuineness of the transactions in such a situation when any sum was credited in the books of the account of the assessee as the provision of section 68 of the Act. It is also relevant to mention here that in case of any one of the condition i.e. either identity of the investor or creditworthiness of the investor or genuineness of the transaction. In the instant case, the genuineness of the transaction found to be non genuine as per the detailed discussed by the AO in the remand report.

6.

1 In this case, it is observed from the submission of the appellant that the appellant has almost reiterated the same facts/submission which was filed before the AO. It is important to mention here that during the course of assessment proceedings, the AO had issued various notices including show cause notices i.e. letter dated 01.06.2018, show cause notice dated 13.07.2018, letter dated 31.07.2018, show cause notice dated 21.09.2018, by which the AO had clearly informed the appellant about the requirement of documents/explanation as per section 68 of the Act. This clearly shows that the appellant was very well aware about the requirement of documents/explanation well before the passing of assessment order dated 29.11.2018. However, the appellant was failed to furnish the required documents/explanation specially in such situation when the said lender was company's director.

6.

2 The submission of the assessee has been carefully examined and considered. Through these submission also, the assessee has not furnished the Income Tax returns of the lender though the lender was a promoter director of the appellant company. Thus, the lender is a closely related person and the onus is heavier on the appellant to prove the credits. The assessee's contention that the lender ShriSanjivPuri had substantial earning from salary and the amount was advanced through banking channel is not acceptable for the reasons that the AO has clearly pointed out that the bank statement of the lender Shri SanjivPuri shows that the payment of Rs.1,00,00,000/- was made on 03.06.2015 and there were two deposits of Rs.50,00,000/- each on23.05.2015. Prior to this date, the available balance in the account of the lender was only Rs.5,50,881/-. Hence, the contention of the assessee that the amount was paid out of salary income is not acceptalbe. It is apparent that the amount of Rs.1,00,00,000/- was transferred out of deposits of Rs.1,00,00,000/- just before the alleged transfer. The source of these two deposits has to be proved beyond the shadow of reasonable doubt. The contention of the assessee that the payments were made through banking channel hence the transaction is genuine is also not acceptable because, the lender Shri Sanjiv Puri in his reply dated 18.10.2018 had stated that he had received the said credit of Rs.50,00,000/- from a close related party as repayment of loan which was given earlier as interest free loan from his salary income but the lender Shri SanjivPuri has not furnished any necessary supporting evidences in support of his claim, which shows that he has nothing to explain or furnish in support of the said two deposits of Rs.50,00,000/-. It is also relevant to mention here that in the said reply dated 18.10.2018, the lender has also admitted that he had not filed any Income Tax Return for A.y.2014-15,

10 Α.Υ.2015-16 & A.Y.2016-17. Thus, the creditworthiness and genuineness of the lender remained unexplained. ………. ……….

8.

In view of the above factual discussion and legal matrix of the case, the addition made by the AO is justified and hence confirmed. Thus, the grounds of appeal no. 1 to 6 are dismissed.”

4.

Dissatisfied, the assessee is in appeal before the Tribunal, raising the following grounds of appeal:

“1. Order of the Hon'ble CIT(A) is bad in law and contrary to the provisions of the Act and facts of the case

1.

1 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in upholding the addition of INR 1,00,00,000 made by the Learned Assistant Commissioner of Income-tax, Circle 1(2), Pune ('Ld. ACIT') towards 'unexplained cash credit' under section 68 of the Act.

1.

2 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in law and in fact in concluding that the Appellant failed to discharge its onus to prove the creditworthiness of Mr. Sanjiv Puri ('the Lender') as well as the genuineness of the transaction, as required under section 68 of the Act, without considering the documentary evidence submitted by the Appellant and without adjudicating on the decisions relied upon by the Appellant to support its contentions.

2.

Creditworthiness of the Lender and genuineness of transaction rebutted on the basis of non-filing of return of income by the Lender

2.

1 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in concluding that the creditworthiness and genuineness of the Lender remained unexplained on account of non-filing of return of income by the Lender, without considering the fact that the Appellant has discharged its onus as required under section 68 of the Act by submitting the documentary evidence to support the creditworthiness of the Lender and the genuineness of the transaction.

2.

2 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in not appreciating the fact that non-filing of return of income by the Lender is beyond the control of the Appellant.

2.

3 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in not considering the reply submitted by the Lender against the notice issued under section 133(6) of the Act.

3.

Creditworthiness of the Lender and genuineness of transaction rebutted on the basis of credit entries in the bank account of the Lender

3.

1 On the facts and in circumstances of the case, the Hon'ble CIT(A) erred in concluding that the Lender is not creditworthy and the transaction is not genuine on account of certain credit entries in the bank account of the Lender, without appreciating the fact that the Lender is also a Director of the Appellant and that the Appellant has paid a considerable amount of the salary to the Lender, providing a reasonable basis for the Appellant to not doubt the source of money advanced by the Lender.

3.

2 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in placing reliance on the decision of the Hon'ble Delhi High Court in the 11

3.

3 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in placing reliance on the decisions of the Hon'ble Mumbal Tribunal in the cases of J. K. Global vs ITO (2024) 167 taxmann.com 15, Income-tax Officer vs. Sal Everest Building & Developers (2022) 142 toxmann.com 383 and DCIT vs. Leena Power Tech Engineers (P) Ltd (2021) 130 taxmann.com 341 as well of the Hon'ble Ahmedabad Tribunal in the case of Pavankumar M Sanghvi vs. Income-tax Officer (2017) 81 taxmann.com 308 wherein loans were availed through shell companies as against the instant case wherein the Appellant has availed loan from its own Director to whom it has been paying a considerable amount of salary.

3.

4 On the facts and circumstances of the case, the Hon'ble CIT(A) erred in placing reliance on the Apex Court's decision in the case of PCIT vs. NRA Iron & Steel (P.) Ltd (2019) 103 taxmann.com 48 (SC) wherein the investor companies were either not in existence or they had filed their tax returns with negligible income. In the instant case, even though the Lender has not filed his income-tax return for the captioned AY 2016-17, the Assessee has proved the creditworthiness of the Lender by submitting the Form 16 of FY 2014-15 and FY 2015-16 issued to him and the bank statement of the Appellant clearly highlighting the salary payments.

3.

5 The Hon'ble CIT(A) has erred in relying on the decision of the Hon'ble Mumbai Tribunal in the case of M/s Zodiac Developers (India) Pvt Ltd. vs. ITO 11(3)(4), Mumbai (ITA No. 1407 /Mum/2020 since the same was recalled in entirety and was fixed for fresh hearing by the Hon'ble Tribunal vide its order dated 07.09.2022. 4. Incorrect observation that the onus to prove creditworthiness of the Lender and genuineness of the transaction is not discharged by the Appellant

4.1.

On the facts and circumstances of the case, the Hon'ble CIT(A) erred in concluding that the Appellant has not submitted relevant evidence to discharge the onus set upon it by the provisions of section 68 of the Act, without considering the exhaustive submissions and documentary evidence submitted to discharge the onus to prove the credit worthiness of the Lender and genuineness of the transaction.

4.2.

On the facts and circumstances of the case, the Hon'ble CIT(A) erred in law in concluding that the Appellant is required to explain the source of receipts in the hands of the Lender to discharge the onus set upon it by section 68 of the Act, without adjudicating the decisions relied upon by the Appellant to support its contention.

4.3.

On the facts and circumstances of the case, the Hon'ble CIT(A) erred in placing reliance on the decision of the Hon'ble Delhi High Court in the case of CIT vs. N. R. Portfolio P ltd (2014) 222 taxman 157 (Delhi) wherein the onus to prove the genuineness of the transaction was shifted back to the assessee since the share applicants were not contactable. The facts of the said decision are distinguishable in the facts of the Appellant's case and therefore, not applicable.

4.4.

On the facts and circumstances of the case, the Hon'ble CIT(A) erred in placing reliance on the decision of the Hon'ble Delhi High Court in the case of CIT vs. Focus Exports Pvt. Ltd. (2014) 51 Taxman 46 (Delhi) wherein the assessee had failed to co-operate during the assessment proceedings and the summons issued to the Directors of the Appellant

12 under section 131 of the Act remained unanswered. The facts of the said decision are distinguishable from the instant case of the Appellant as the Appellant submitted all the documents to the extent available and the Lender also responded to the notice issued under section 133(6) of the Act.

5.

On the facts and circumstances of the case, the Hon'ble CIT(A) erred in disregarding various case laws relied upon by the Appellant and not providing any rebuttal for any case laws relied upon by the Appellant.

6.

Wrongful disallowance of carry forward of MAT credit On the facts and circumstances of the case, the Hon'ble CIT(A) has erred in disallowing the carry forward of MAT credit available to the Appellant.

7.

Wrongful levy of interest under section 234A and 234B of the Act On the facts and circumstances of the case, the Hon'ble CIT(A) has erred in dismissing the ground with respect to the levy of interest under section 234A of the Act without considering the due date for filing return of income applicable to the Appellant.

8.

Wrongful levy of interest under section 2348 of the Act. On the facts and circumstances of the case, the Hon'ble CIT(A) has erred in dismissing the ground with respect to the levy of interest under section 234B of the Act.

9.

Wrongful levy of penalty On the facts and circumstances of the case, the Hon'ble CIT(A) has erred in law and in facts in not adjudicating on the ground of the Appellant requesting to set aside the penalty proceedings initiated by the Ld. ACIT under section 271(1)(c) of the Act.”

5.

The Ld.AR submitted that although number of grounds have been raised by the assessee, the sole issue for adjudication in the present appeal is whether addition made by the Ld. AO and confirmed by the Ld.CIT(A)/NFAC u/s. 68 of the Act is sustainable or not under the present facts and circumstances of the case? He submitted that identity and financial capacity of the lender, Mr. Sanjiv Puri is not disputed by the Ld.AO and Ld.CIT(A)/NFAC. Relying on the documentary evidences filed before the lower authorities, the Ld.AR submitted that the assessee has already established the genuineness of the transaction of unsecured loan of Rs. 1,00,00,000/- borrowed from Mr. Sanjiv Puri by the assessee company. The Ld.AR submitted that the Ld.AO / Ld.CIT(A)/NFAC had doubts about the two deposit entries of Rs. 50,00,000/- each credited in Mr. Sanjiv Puri‟s account when he lent the money to the assessee. To rebut the same, the Ld.AR submitted that Mr. Sanjiv Puri had submitted his reply to the notice issued u/s. 133(6) of the Act on 18-10-2018

13 explaining the source of the said credits (pg. 284-285 containing the reply of Mr. Sanjiv Puri refers). The Revenue has not brought on record any contrary material to disprove the submission of Mr. Sanjiv Puri.

5.

1 Without prejudice, the Ld.AR submitted that the assessee is not required to prove source of source for the relevant AY 2016-17 under consideration. He submitted that the law is amended w.e.f. 01-04-2023 to cast the burden on the assessee to explain the source of source. He, therefore, submitted that the Ld.AO erred in making the impugned addition in the hands of the assessee as the amended provisions are not applicable to the assessee for the relevant AY. 2016-17. 5.2 In support of his above contention, the Ld.AR placed relied on the decision(s) of the Pune Bench of the Tribunal in the case of – (i) Dhaval Vinod Gada vs. DCIT, in ITA No. 1817/PUN/2025, AY. 2013-14, dt. 03-12-2025 and (ii) Prem Grain Industries Pvt. Ltd. vs. DCIT, in ITA No. 2012/PUN/2025, AY. 2016-17, dt. 20-11-2025. 5.3 He further relied on the decision(s) of the Hon‟ble Delhi and Gujarat High Court in the cases of Sheela Overseas (P.) Ltd. vs. PCIT [2026] 183 taxmann.com 236 (Delhi) and Laxmi Infra Developers Ltd. vs. ACIT [2026] 184 taxmann.com 636 (Gujarat), respectively.

5.

4 Without prejudice to his above arguments, the Ld.AR raised another contention that if at all any addition is called for, it should be made in the hands of Mr. Sanjiv Puri, who has lent the money to the assessee and not in the hands of the assessee.

14

5.

5 Another line of argument taken by the Ld.AR is that since the loan is repaid, interest is paid and TDS on interest has been deducted and the interest is not disallowed by the Ld.AO, the addition made by the Ld.AO is not sustainable. The Ld.AR submitted that loan amount has been repaid in the subsequent year and interest @ 11% is paid to Mr. Sanjiv Puri on which TDS has been duly deducted, which has been allowed by the Ld.AO. (2025) 174 taxmann.com 1130 (Delhi – Trib), the Ld.AR submitted that if the interest is not disallowed, then addition u/s. 68 of the Act cannot be made as both are consequential.

5.

6 Lastly, the Ld. counsel for the assessee relied on the decision of the Co-ordinate Bench of the Tribunal in the case of Ramesh Baburam Chauhan vs. ITO in ITA No. 3174/PUN/2025, AY. 2012-13, dt. 27-03- 2026, wherein it has been held that there are no set procedures to establish the genuineness of loan. The Ld. AR submitted that the amount borrowed from Mr. Sanjiv Puri and interest paid thereon has also been reported by the assessee company under the provisions of the Companies Act, 2013 to the concerned regulatory authorities and hence, the transaction cannot be regarded as non-genuine.

5.

7 So far as the other grounds relating to MAT credit, levy of interest and initiation of penalty proceedings are concerned, the Ld.AR submitted that these are either consequential or pre-matured and to be dealt with accordingly.

6.

The Ld. DR, on the other hand, strongly supported the order of the Ld.AO and Ld.CIT(A)/NFAC.

15

7.

We have heard the Ld. Representatives of the parties, perused the material available on record, Paper Book filed by the Ld. AR on behalf of the assessee as well as the judicial precedents cited by the Ld. AR. The facts of the case are not disputed. We find that the Ld. AO has completed the assessment u/s 143(3) of the Act on 29.11.2018 thereby making an addition of Rs.1,00,00,000/- to the income of the assessee as unexplained credits u/s 68 of the Act holding that creditworthiness of the lender is not proved due to absence of ITR of the lender and the amount of Rs. 1,00,00,000/-(two credit deposits of Rs. 50,00,000/- each) is not given from the salary sourced by the lender, who is promoter-director of the assessee company and hence the transactions are not genuine. The Ld. CIT (A)/NFAC confirmed the addition made by the Ld. AO for the reasons which we have already reproduced in the preceding paragraphs. Before us, relying on various documents/details submitted before the lower authorities, the Ld. AR has submitted that the assessee has proved all the three ingredients u/s 68 of the Act and therefore the addition made by Ld. AO and confirmed by the Ld. CIT(A)/NFAC is unsustainable in law. From the perusal of the factual paper book filed by the Ld. AR, we find that the following documents/details were submitted before the Ld. AO/CIT(A)/NFAC : i. Tax audit annexures of the assessee where the particulars of loan have been disclosed along with information of TDS u/s 194A on interest paid to the lender. (page no. 135 to 138 of the Factual Paper Book refers) ii. Loan confirmation given by the lender (page no. 206 of the Factual Paper Book refers) iii. PAN of the lender (page no. 207 of the Factual Paper Book refers)

16 iv. Form No. 16 for AY 2016-17 of the lender reflecting salary paid by the assessee to the lender as he was director of the assessee company (page no 208 to 217 of the Factual Paper Book refers) v. Bank statement of the company where salary payment to the director and receipt of loan from him are reflected (page no. 218 to 273 of the Factual Paper Book refers) vi. Bank statement of the lender where the loan given to the assessee is reflected (page no. 274 of the Factual Paper Book refers) vii. Bank statement of the lender for preceding year AY 2015-16 reflecting salary paid by the company to the lender. (page no 275 to 283 of the Factual Paper Book refers) viii. Response filed by the lender dated 18.10.2018 to the notice issued u/s 133(6) to the lender (page no 284 to 285 of the Factual Paper Book refers). ix. Other documents such as driving license and passport of the lender is enclosed at page no. 286 to 288 of the Factual Paper Book for establishing identity.

8.

Further, from the bank account extract of the lender where the two credits deposits of Rs. 50,00,000/- each is reflected, it is observed that these entries are appearing on 23.05.2015 and 3.06.2015 received from the party "NAC Lifescience" through RTGS (page no. 274 of the Factual Paper Book refers). It is also observed that the lender filed reply to the Ld. AO in response to notice u/s 133(6) on 18.10.2018 wherein he duly explained the source of such credits (page no. 284 -285 of the Factual Paper Book refers). Admittedly, the ITR of the lender, Mr. Sanjay Puri for AY-2016-17 could not be furnished for the reason that he did not file the same due to his non-resident status for the relevant AY. The Revenue has not brought any contrary material on record to controvert the contentions/submissions of the Ld. AR. We, therefore, find some force in the argument advance by the Ld. AR that there was no reason to hold that 17 the amount received by the assessee is not sourced from the lender. In our considered view addition u/s 68 is unsustainable in the present facts of the case and in law.

9.

Without prejudice, the Ld. Counsel for the assessee has submitted that the assessee is not required to prove the source of source for relevant AY 2016-17 under consideration. In support thereof, the Ld. AR has relied on the decision of the coordinate bench of the Tribunal in the case of Dhaval Vinod Gada (supra) wherein following the earlier decision of the Tribunal in the case of Prem Grain Industries Pvt. Ltd. (supra) and the Hon‟ble Delhi High Court in the case of Sheela Overseas (P) Ltd (supra), it was held that the amendment to section 68 of the Act introduced by virtue of the Finance Act 2022 makes it abundantly clear that section 68 of the Act as was in force prior to 01.04.2023 did not require the assessee to explain the source of source other than share application money, share capital, share premium or any amount of such nature and the addition made u/s 68 of the Act was therefore deleted.

10.

We find that the coordinate bench in Dhaval Vinod Gada‟s case (supra) held as under:

“11. We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A)/NFAC and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the instant case made addition of Rs.1.62 crores u/s 68 of the Act on the ground that the assessee has accepted loan of Rs.1.62 crores from Shri Manilal Gada who in turn has received the said amount from his wife Smt. Neeta Manilal Gada and Smt. Neeta Manilal Gada has obtained the loan from Shri Shantilal Shah, Smt. Nenshi L. Shah and Shri Lalji K. Shah who are the vendors of the said land. According to the Assessing Officer the entries of loan were taken and repaid and land of Rs.3.24 crores was purchased by the assessee and his brother. The ultimate beneficiary was the assessee and his brother by accommodating entries of loan. We find the Ld. CIT(A) / NFAC while sustaining the addition has relied on the decision of the Hon'ble Supreme Court in the case of PCIT vs. M/s. NRA Iron and Steel Pvt. Ltd. (supra). It is the submission of the Ld. Counsel for the assessee that the decision of Hon'ble Supreme Court in the case of PCIT vs. M/s. NRA Iron and Steel Pvt. Ltd. (supra) is not applicable to the facts of the present case. Further the assessee in the instant case has explained the source of source.

18 It is his submission that in view of the decision of Hon'ble Delhi High Court in the case of Sheela Overseas Pvt. Ltd vs. PCIT (supra) where it has been held that amendment to section 68 of the Act introduced by virtue of the Finance Act, 2022 makes it abundantly clear that section 68 of the Act, as was in force prior to 01.04.2023, did not require the assessee to explain the source of the source of funds other than share capital money, share capital, share premium or any amount of such nature, therefore, no addition u/s 68 can be made.

12.

We find some force in the above arguments of the Ld. Counsel for the assessee. It is an undisputed fact that the assessee during the course of assessment proceedings has explained the source of Rs.1.62 crores being the loan taken from Shri Manilal M. Gada. It is also an undisputed fact that Shri Manilal M. Gada in response to the notice u/s 133(6) of the Act has submitted his reply along with his bank statement according to which he has given an amount of Rs.1.62 crores as loan to the assessee. There is no doubt that Shri Manilal M. Gada has obtained loan of equal amount from his wife Smt. Neeta Manilal Gada who in turn has obtained loan of equal amount from the vendors Shri Shantilal Shah, Smt. Nenshi L. Shah and Shri Lalji K. Shah. It is also an undisputed fact that identical amount of loan obtained by the brother for purchase of 50% share in the property has been accepted and no addition has been made by the Assessing Officer nor anything was brought to our notice that any action u/s 147 or 263 of the Act has taken place. Under these circumstances we have to see as to whether any addition can be made in the hands of the assessee u/s 68 of the IT Act where he has not only explained the source but has also explained the source of the source.

13.

We find the Hon'ble Delhi High Court in the case of Sheela Overseas Pvt.

14.

We find following the above addition, the Coordinate Bench of the Tribunal in the case of Prem Grain Industries Pvt. Ltd. Vs. DCIT (supra) has deleted the addition made by the Assessing Officer u/s 68 of the Act and sustained by the Ld. CIT(A)/NFAC by observing as under:

"

16.

We have heard the rival arguments made by both the sides, perused the orders of the Assessing Officer and Ld. CIT(A) and the paper book filed on behalf of the assessee. We have also considered the various decisions cited before us. We find the Assessing Officer in the instant case made addition of Rs. 1,15,00,000/-w/s 68 of the Act being the amount of loan obtained from Risa International Ltd by the assessee on the ground that mere submission of documents such as PAN, copies of ITRs, account confirmations, repayment with interest and TDS thereon cannot by itself discharge the burden cast upon the assessee u/s 68 of the Act. According to him, in terms of section 68 of the Act, the assessee has to prove the identity and creditworthiness of loan creditors and the genuineness of the transaction. According to him, in the instant case the true identity of the loan creditor Risa International Ltd is not proved and its creditworthiness was also is doubtful since Risa International is just a paper company used by the beneficiaries of Risa International Ltd to provide accommodation entries. We find the Ld. CIT(A) sustained the addition made by the Assessing Officer. It is the submission of the Ld. Counsel for the 19 assessee that the assessee has filed all the relevant details such as PAN, copies of ITRs, account confirmations, repayment with interest and TDS thereon, bank statement etc to prove the identity and creditworthiness of the loan creditor and genuineness of the transaction. The director of Risa International Ltd, lender company has appeared before the Assessing Officer in response to the summons u/s 131 of the Act and has confirmed to have extended the loan of Rs.1,15,00,000/- out of collections from sundry debtors. He has also stated to have extended the loan to the company where his father-in-law is the Director. It is also his submission that in view of the amendment to section 68 of the Act prior to 01.04.2023 the assessee is not required to explain the source of the source of funds other than share capital money, share capital, share premium or any amount of such nature.

17.

We find some force in the arguments of the L.d. Counsel for the assexser It is an admitted fact that the assessee during the course of assessment proceedings has filed various details such as return of income, computation of income, copy of audit report, copy of unsecured loans along with confirmation and other relevant details etc. This fact has been admitted by the Assessing Officer at para 4 in the body of assessment order. It is also an admitted fact that in response to the summons uws 131 of the Act, Shri Abhinandan Jain, director of Risa International Lid had appeared before the Assessing Officer whose statement was recorded wherein he has confirmed to have given loan of Rs. 1,15,00,000/- to M/s. Prem Grain Industries Pvt Ltd, a company in which his father-in-law is the Director. He has also stated in the statement that the amounts of credit in the bank account of Risa International Ltd is out of the amount recovered from the debtors. He has also stated that the company has received back the entire amount by 08.06.2017. The details of the statement so recorded of Shri Abhinandan Suresh Jain are as under: ……….

18.

We find the Hon'ble Delhi High Court in the case of Sheela Officer and has confirmed to have given the loan of Rs. 1,15,00,000/- out of the amount received from sundry debtors which in turn has already been repaid by 08.06.2017, therefore, in our opinion, the assessee has fully discharged its onus cast upon it by proving the three ingredients of section 68 Le identity. creditworthiness of lenders and genuineness of the transaction, We, therefore, set aside the order of the Ld. CIT(A) and direct the Assessing Officer to delete the addition. Grounds raised by the assessee are accordingly allowed."

15.

Since in the instant case the assessee has filed the requisite details explaining the source of Rs.1.62 crores being the loan obtained from Shri Manilal M. Gada and Shri Manilal M. Gada in response to notice u/s 133(6) of the Act has also confirmed to have given the said loan and has filed his

20 bank statement explaining the source, therefore, in our opinion, the assessee has fully discharged the onus cast upon him in terms of section 68 by proving the three ingredients i.e. identity and creditworthiness of Shri Manilal M. Gada and the genuineness of the transaction. We, therefore, set aside the order of the Ld. CIT(A)/NFAC and allow the grounds raised by the assessee.

16.

In the result, the appeal filed by the assessee is allowed.”

11.

Thus, considering the totality of facts and the legal position set out above, we are of the considered view that the assessee has produced sufficient material required to establish- (i) identity of the source, (ii) creditworthiness of such source and (iii) genuineness of the transaction and hence has fully discharged the onus cast upon the assessee u/s 68 of the Act by proving the aforesaid three ingredients of section 68 of the Act.

12.

Since we have already taken a view in favor of the assessee, we refrain ourselves from opining on the alternate contention(s) raised by the Ld. AR stated in Para 5.4 to 5.6 of our order above. We, therefore, set aside the order of Ld. CIT(A)/NFAC and allow the effective grounds raised by the assessee. The other grounds raised by the assessee i.e. ground no. 6 relating to disallowance of carry forward of MAT credit and ground no. 7 & 8 relating to levy of interest u/s 234A and 243B of the Act are consequential in nature. Ground no. 9 relates to initiation of penalty proceedings u/s 271(1)(c) which does not require adjudication being premature.

13.

In the result, the appeal of the assessee is allowed. Order pronounced in the open Court on 25-06-2026 (RAMA KANTA PANDA) (ASTHA CHANDRA) VICE PRESIDENT JUDICIAL MEMBER पुणे/Pune; Tadepalli Naga Naga Murali Mohan दिन ांक/Dated : 25-06-2026 Murali Mohan Date: 2026.06.30 12:17:32 +05'30' TNMM

21 आदेश की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to: अपील र्थी / The Appellant 1. 2. प्रत्यर्थी / The Respondent

3.

The concerned Pr.CIT, Pune

4.

DR, ITAT, „A‟ Bench, Pune 5. ग र्ड फ ईल / Guard file. आदेशानुसार/ BY ORDER, ////

More judgments on Section 68

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

Recent GST High Court judgments

Search GST case law →