RAADHIYA INDUSTRIES PRIVATE LIMITED,YAMNUNANAGAR vs. ASSESSMENT UNIT-INCOME TAX DEPTT, YAMUNANAGAR
What did the Tribunal hold?
The Tribunal admitted additional evidence, including ledger extracts and financial statements of lenders and the 'source of source', deeming them material. The issue was restored to the AO for fresh consideration.
What were the facts?
The assessee's unsecured loans increased by Rs. 296.24 Lacs, which the AO added to income under Section 68 for failure to substantiate genuineness and creditworthiness of lenders, including the 'source of source'. The CIT(A) upheld this addition.
What were the issues?
Whether the assessee sufficiently substantiated the genuineness and creditworthiness of unsecured loans and their source, and if additional evidence should be admitted.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH
Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI LALIET KUMAR, JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.513/CHANDI/2026 (िनधा�रण वष� / Assessment Year: 2023-24) M/s Raadhiya Industries Pvt. Ltd. Income Tax Officer बनाम/ Vs. Plot #13-15, Tejli Gate, Jagadhari Yamuna Nagar, Haryana Yamuna Nagar (Haryana) – 135003 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AALCR-3178-G (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Neeraj Goel (Advocate) – Ld. AR ��थ�कीओरसे/Respondent by : Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 25-05-2026 घोषणाकीतारीख /Date of Pronouncement : 02-06-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2023-24 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 18.02.2026 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) r.w.s. 144 of the Act on 28.02.2025. 2. During the course of hearing, Ld. AR sought admission of additional evidences and filed an application u/r 29 of ITAT Rules,
1963. The Ld. AR sought admission of the same and pleaded for restoring the matter back to the lower authorities which has been opposed by Ld. Sr. DR. 3. From the case records, it could be seen that in the assessment order, Ld. AO noted that there was increase in unsecured loans by Rs.296.24 Lacs during this year. These loans were received from nine lenders which are tabulated at Page-3 of the impugned order of Ld. CIT(A). The assessee failed to substantiate the genuineness of these loans as well as creditworthiness of the lender parties. The rejection was primarily on the ground that the assessee could not substantiate the ‘source of source’ of these loans. Accordingly, the same were added to the income of the assessee u/s 68. The Ld. CIT(A) endorsed the findings of Ld. AO for want of any further documentary evidences from the assessee. Aggrieved, the assessee is in further appeal before us. 4. The additional evidences which are sought to be considered by Ld. AR include Ledger Extracts of lender parties, audited financial statements, bank statements and confirmation of M/s Hindustan Industries Ltd. (source of source), bank statements of the assessee entity. It has been stated that the assessee was prevented by sufficient cause from producing these comprehensive documents since the detailed consolidation and presentation of the ‘source of source’ across multiple entities and financial years required extensive compilation and analysis and this exercise has now been completed.
Upon perusal of these documents and evidences, we are of the considered opinion that these would have material bearing on the impugned issue. Therefore, keeping in mind the principles of natural justice, we admit the same and restore the sole issue of addition u/s 68 for Rs.296.24 Lacs back to the file of Ld. AO for fresh consideration with a direction to the assessee to plead and prove its case forthwith. No other ground has been urged in the appeal. 6. The appeal stand partly allowed for statistical purposes. Order pronounced on 02nd June, 2026.
-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated:02-06-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF
ASSISTANT REGISTRAR
ITAT CHANDIGARH
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