ACIT CC 7(3), MUMBAI vs. TRISHUL REALTY INFRA LLP, MUMBAI

ITA 7649/MUM/2025Status: DisposedITAT Mumbai19 February 2026AY 2012-13Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee had discharged its onus by providing documentary evidence for the loan received. The Tribunal further stated that the assessee is not required to prove the genuineness of the transaction between the intermediary and the original lender (source of source), especially for unsecured loans.

What were the facts?

The Revenue appealed against the CIT(A)'s deletion of an addition of Rs. 40,00,000/- made under Section 68. The addition was for an alleged accommodation entry received by the assessee through an intermediary, from a company identified as a shell company by the Investigation Wing.

What were the issues?

Whether the assessee discharged its burden under Section 68 by proving the genuineness of the loan received, and whether the assessee was required to prove the genuineness of the transaction between the intermediary and the original lender.

Which sections of the Income-tax Act were involved?

Section 68

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Income Tax Appellate Tribunal, “SMC” BENCH, MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI PRABHASH SHANKAR

For Appellant: Shri Rushabh Mehta
For Respondent: Shri Brajendra Kumar (SR. DR.)
Hearing: 09.02.2026Pronounced: 19.02.2026

Heard together (2 matters)

I.T.A. No. 7649/Mum/2025
CO. No. 33/Mum/2026

Read from the judgment's own cause title. This page is filed under one of them.

Per Sandeep Gosain, JM:

Trishul Realty Infra LLP The present appeal has been filed by the Revenue and cross objection by the assessee challenging the order dated 29.09.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / C

The order continues below.

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