PR. CIT-1 vs. UMA SINGAL
What did the High Court hold?
The ITAT upheld the deletion of additions because the assessee was not provided with a copy of the statement of the alleged provider of accommodation entries, nor was an opportunity for cross-examination given. The Revenue failed to controvert this factual finding.
What were the facts?
The Assessing Officer made additions to the assessees' income on account of unexplained credits received as accommodation entries. The CIT(A) deleted these additions, and the ITAT affirmed this deletion.
What were the issues?
Whether additions made on account of unexplained credits are valid when the assessee is denied the opportunity to cross-examine the source of such credits.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
ITA No. 689/2015 Connected batch Page 1 of 4
$~ * IN THE HIGH COURT OF DELHI AT NEW DELHI 1. +
ITA 689/2015
PR. CIT-1
..... Appellant Through Mr.N.K. Sahni, Senior Standing counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
UMA SINGAL
..... Respondent
Through:
WITH 2.
ITA 690/2015
PR. CIT(C)-1
..... Appellant Through Mr.N.K. Sahni, Senior Standing counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
BRIJ BHUSHAN SINGAL
..... Respondent
Through
WITH 3. +
ITA 691/2015
PR. CIT(C)-1
..... Appellant Through Mr.N.K. Sahni, Senior Standing counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2026 at 21:53:54
ITA No. 689/2015 Connected batch Page 2 of 4
BRIJ BHUSHAN SINGAL
..... Respondent
Through
WITH 4. +
ITA 692/2015
PR.CIT
..... Appellant Through Mr.N.K. Sahni, Senior Standing counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
UMA SINGAL
..... Respondent
Through
WITH 5. +
ITA 693/2015
PR. CIT
..... Appellant Through Mr.N.K. Sahni, Senior Standing counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
M/S BHUSHAN ENERGY LTD
..... Respondent
Through
WITH 6. +
ITA 694/2015
PR CIT
..... Appellant Through Mr.N.K. Sahni, Senior Standing Counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
NEERAJ SINGAL
..... Respondent This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2026 at 21:53:54
ITA No. 689/2015 Connected batch Page 3 of 4
Through
AND 7. +
ITA 744/2015
PR.CIT
..... Appellant Through Mr.N.K. Sahni, Senior Standing counsel with Mr.Nitin Gulati, Junior Standing Counsel.
versus
BRIJ BHUSHAN SINGAL
..... Respondent
Through
CORAM: HON'BLE DR. JUSTICE S.MURALIDHAR HON'BLE MR. JUSTICE VIBHU BAKHRU
O R D E R %
05.10.2015
CM 18306/2015 in ITA 689/2015 CM 18308/2015 in ITA 690/2015 CM 18309/2015 in ITA 691/2015 CM 18313/2015 in ITA 692/2015 CM 18314/2015 in ITA 694/2015 CM 21185/2015 in ITA 744/2015
Allowed, subject to all just exceptions. 2. The applications stand disposed of. ITA 689/2015 ITA 690/2015 ITA 691/2015 ITA 692/2015 ITA 693/2015 ITA 694/2015 ITA 744/2015 3. These appeals are directed against the common impugned order dated This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2026 at 21:53:54
ITA No. 689/2015 Connected batch Page 4 of 4
17th February, 2015 passed by the ITAT in ITA No. 2481/DEL/2013 for the Assessment Year 2004-05, 2005-06 and 2007-08.
The question concerns the deletion of additions made by the Assessing Officer on account of unexplained credits received by the Assessee as accommodation entries from Mr S.K. Gupta through his entity namely M/s Sino Credits (P) Limited.
The ITAT in the impugned order affirmed the order of the CIT (A) deleting the addition on two grounds, one of which was that although reliance was placed on the statement of Mr S.K. Gupta neither was a copy of the said statement given to the Assessee nor was the Assessee given an opportunity to cross-examine Mr S.K. Gupta. This factual finding has been unable to be controverted by the Revenue by bringing on record any material.
Consequently, no substantial question of law arises.
The appeals are dismissed.
S.MURALIDHAR, J
VIBHU BAKHRU, J OCTOBER 05, 2015 pkv This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 04/04/2026 at 21:53:54
More judgments on Section 68
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Bliss Dealtrade Private Limited, Kolkata vs Income Tax Officer - Ward 9(2) Kolkata…ITA 208/KOL/2026[2012-13]Status: Disposed21 Oct 2026AY 2012-13
- Hemal Paresh Madeka, Rajkot vs Asst.Commissioner of Income Tax…ITA 955/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
- Ajaybhai Dineshbhai Bagdai, Near Central… vs The Income Tax Officer, Ward-1(2)(1), New…ITA 74/RJT/2026[2013-14]Status: Disposed19 Oct 2026AY 2013-14
Recent GST High Court judgments
Search GST case law →- M/S Imperial Marketing vs. Principal Commissioner Of CGST Delhi NorthDelhi · 28 Oct 2026
- M/S Om.S.R. Construction, Through Its Proprietor Mr. Kuldeep Sharma vs. The State Of Jharkhand Through Its Commissioner, Commerical Tax DepartmentJharkhand · 28 Oct 2026
- M/S. Bhanwal Trading And Company vs. The Union Of INDIARajasthan · 28 Oct 2026
- M/S. Saraswati Enterprises vs. State Of RajasthanRajasthan · 28 Oct 2026
- Akshaya Consortium vs. The Assistant Commissioner (St)Andhra Pradesh · 28 Oct 2026