What is 2011) ITO v. Rakam Money authority for?

A transaction that is purely paper-based and lacks genuine substance cannot entitle an assessee to claim a benefit under the law, even if a paper trail has been created. The onus is on the assessee to establish the genuineness of the transaction.

How many judgments cite 2011) ITO v. Rakam Money?

34 judgments on BharatTax cite 2011) ITO v. Rakam Money (253 ITR 341), spanning 2016 to 2025.

Which sections of the Income Tax Act does 2011) ITO v. Rakam Money come up under?

It is most often cited in judgments turning on Section 147, Section 148, Section 145(3), Section 69C, Section 142(1), Section 151.

2011) ITO v. Rakam Money (253 ITR 341)

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. S S PULSES MANUFACTURING PVT LTD, DELHI

In the result, the appeal is partly allowed

ITA 2384/DEL/2024[2012]Status: DisposedITAT Delhi09 Dec 2025

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR

Section 143(3)Section 147Section 148Section 69C

…nel but these were ultimately settled in cash. Merely because a paper trail had been created, that would not by itself make the transaction genuine. It was held by Hon’ble Punjab & Haryana High Court in the case of Mittal Belting and Machinery Stores Vs. CIT (253 ITR 341) that if on the examination of the evidence, it is found that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon’ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by…

ANSHUMAN AUTO IMPEX PRIVATE LIMITED,NEW DELHI vs. INCOME TAX OFFICER, WARD 2(1), NEW DELHI

In the result, the appeal is dismissed

ITA 4152/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Oct 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2016-17 Vs. Income Tax Officer, Anshuman Auto Impex Pvt. Ltd., Ward-2(1), 2126/59, Laxmi Bhawan, New Delhi Naiwala, Karol Bagh, New Delhi Pan: Aaaca0872H (Appellant) (Respondent) Assessee By None Department By Sh. Manish Gupta, Sr. Dr

Section 147Section 148

…payment by account payee cheque is not sacrosanct nor can it make a non-genuine transaction genuine in that view of the matter, the question before us is answered in the negative and in favour of the revenue." In Mittal Belting & Machinery Stores vs CIT (P&H) 253 ITR 341, The Hon'ble Punjab & Haryana High Court held that "If on examination of evidence, it is found that there was no genuine Transaction between the parties, a pure paper Transaction can not entitle assessee to claim benefit under the law Mere on basis of paper Transaction, the same does not become genuine 6.2.5 The onus was on the appellant to estab…

DCIT, NEW DELHI vs. SH. NIRANJAN KOIRALA,, NEW DELHI

In the result, appeal of the Revenue is dismissed

ITA 2253/DEL/2010[2006-07]Status: DisposedITAT Delhi19 Aug 2025AY 2006-07

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.2253/िद"ी/2010(िन.व. 2006-07) Deputy Commissioner Of Income Tax, Circle-31(1), R. No. 1405, 14Th Floor, E-2 Block, Pratyakshkar Bhawan, Civic Centre, Jln Marg, ...... अपीलाथ"/Appellant New Delhi बनाम Vs. Niranjan Koirala, 27, Akbar Road, New Delhi ..... "ितवादी/Respondent Pan: Aaupk-0483-B Assessee By : Shri Tarandeep Singh, Advocate Department By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 23.05.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19.08.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-Xxx, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 18.02.2010, For Assessment Year 2006-07. 2. This Appeal Was Decided By The Tribunal Vide Order Dated 20.07.2018. Thereafter, The Revenue Filed Miscellaneous Application Seeking Rectification In The Order Of Tribunal On The Ground That The Additional Grounds Of Appeal Raised By The Revenue Vide Application Dated 13.08.2014 Remained To Be Decided. The Tribunal In Ma No. 732/Del/2018 Vide Order Dated 10.07.2023 Recalled The Order

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR

Section 54F

…urthy Vs. CIT (2003) 261 ITR 623(Mad); Bhagat Construction Co.(P) Ltd Vs. CIT(2001) 250 /TR 291 (Delhi;, Workmen of Association Rubber Industry Ltd. Vs. Associated Rubber Industry Ltd. (1986) 157 ITR 77 (SC;, Mittal Belting and Machinery Stores Vs. CIT (2002) 253 ITR 341 (P&H), Avasasala Automation Ltd. Vs. JCIT (2004) 266 ITR 178 (Kar.). 2.6 A show cause letter was issued to the assessee on 21.10.2008 asking him to explain as to why the claim of deduction u/s 54F may not be rejected. Assessee has filed his reply on 3.11.2008. The reply of the assessee has been examined in detail. The assessee has reiterated its…

DEPUTY COMMISSIONER OF INCOME TAX-1(1), RAIPUR vs. SHANTA TECHNO PRIVATE LIMITED, RAIPUR

ITA 155/RPR/2025[2018-19]Status: DisposedITAT Raipur18 Jun 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 155/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 142(1)Section 147Section 148Section 250Section 69C

…nel but these were ultimately settled in cash. Merely because a paper trail had been created, that would not by itself make the transaction genuine. It was held by Hon'ble Punjab & Haryana High Court in the case of Mittal Belting and Machinery Stores Vs. CIT (253 ITR 341) that if on the examination of the evidence, it is found that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. 5 DCIT-1(1) vs. Shanta Techno Private Limited Similarly, the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt…

BARMINCO INDIAN UNDERGROUND MINING SERVICES LLP,DELHI vs. DCIT, CIRCLE-28(1), DELHI

In the result, appeal of the Revenue is dismissed

ITA 2253/DEL/2022[2020-21]Status: DisposedITAT Delhi04 Apr 2025AY 2020-21

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.2253/िद"ी/2010(िन.व. 2006-07) Deputy Commissioner Of Income Tax, Circle-31(1), R. No. 1405, 14Th Floor, E-2 Block, Pratyakshkar Bhawan, Civic Centre, Jln Marg, ...... अपीलाथ"/Appellant New Delhi बनाम Vs. Niranjan Koirala, 27, Akbar Road, New Delhi ..... "ितवादी/Respondent Pan: Aaupk-0483-B Assessee By : Shri Tarandeep Singh, Advocate Department By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 23.05.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19.08.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-Xxx, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 18.02.2010, For Assessment Year 2006-07. 2. This Appeal Was Decided By The Tribunal Vide Order Dated 20.07.2018. Thereafter, The Revenue Filed Miscellaneous Application Seeking Rectification In The Order Of Tribunal On The Ground That The Additional Grounds Of Appeal Raised By The Revenue Vide Application Dated 13.08.2014 Remained To Be Decided. The Tribunal In Ma No. 732/Del/2018 Vide Order Dated 10.07.2023 Recalled The Order

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR

Section 54F

…urthy Vs. CIT (2003) 261 ITR 623(Mad); Bhagat Construction Co.(P) Ltd Vs. CIT(2001) 250 /TR 291 (Delhi;, Workmen of Association Rubber Industry Ltd. Vs. Associated Rubber Industry Ltd. (1986) 157 ITR 77 (SC;, Mittal Belting and Machinery Stores Vs. CIT (2002) 253 ITR 341 (P&H), Avasasala Automation Ltd. Vs. JCIT (2004) 266 ITR 178 (Kar.). 2.6 A show cause letter was issued to the assessee on 21.10.2008 asking him to explain as to why the claim of deduction u/s 54F may not be rejected. Assessee has filed his reply on 3.11.2008. The reply of the assessee has been examined in detail. The assessee has reiterated its…

ITO-19(3)(1), MUMBAI vs. THANA RAM MANGI LAL CHOUDHARY, MUMBAI

In the result, the appeal is partly allowed

ITA 2698/MUM/2024[2009-10]Status: DisposedITAT Mumbai29 Aug 2024AY 2009-10

Bench: Shri Amarjit Singh, Hon’Ble & Shri Anikesh Banerjee, Hon’Bleassessment Year: 2009-10 Ito-19(3)(1), Mumbai Thana Ram Mangi Lal Choudhary Vs 33/36, Prabhu Shree Ram Mandir, 4Th Kumbharwada, Maharashtra-400004. Pan: Afepc 1898 P (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri P.D. Chougule Addl. CIT/ Sr. DR

Section 142(1)Section 145(3)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH ‘E’, MUMBAI BEFORE SHRI AMARJIT SINGH, HON’BLE ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, HON’BLE JUDICIAL MEMBER Assessment Year: 2009-10 ITO-19(3)(1), Mumbai Thana Ram Mangi Lal Choudhary vs 33/36, Prabhu Shree Ram Mandir, 4th Kumbharwada, Maharashtra-400004. PAN: AFEPC 1898 P (Appellant) (Respondent) Present for: Assessee by : None Revenue by : Shri P.D. Chougule Addl. CIT/ Sr. DR Date of Hearing : 24.07.2024 Date of Pronouncement : 29.08.2024 O R D E R PER AMARJIT SINGH, AM: The present appeal filed by the assessee is directed against the order dat…

HARISONS STEEL LIMITED,WADA THANE vs. DY CIT 12(2)(2), MUMBAI

In the result, the appeal of the assessee vide ITA No

ITA 3957/MUM/2023[2013-14]Status: DisposedITAT Mumbai10 Jun 2024AY 2013-14

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Mani JainFor Respondent: Biswanath Das

Section 143(3)Section 147Section 148

…nnel but these were ultimately settled in cash Merely because a paper trail had been created, that would not by itself make the transaction genuine. It was held by Hon'ble Punjab & Haryana High Court in the case of Mittal Belting and Machinery Stores Vs. CIT (253 ITR 341) that if on the examination of the evidence, it is found that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by…

HARISONS STEEL LTD,WADA THANE vs. DCIT 12(2)(2) , MUMBAI

In the result, the appeal of the assessee vide ITA No

ITA 3943/MUM/2023[AY 2011-12]Status: DisposedITAT Mumbai10 Jun 2024

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Mani JainFor Respondent: Biswanath Das

Section 143(3)Section 147Section 148

…nnel but these were ultimately settled in cash Merely because a paper trail had been created, that would not by itself make the transaction genuine. It was held by Hon'ble Punjab & Haryana High Court in the case of Mittal Belting and Machinery Stores Vs. CIT (253 ITR 341) that if on the examination of the evidence, it is found that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly, the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 ITD 177) that issue of bills by…

DINESH KUMAR JAIN ,MUMBAI vs. ITO-22(1)(2), MUMBAI

In the result, the appeal of the Assessee is dismissed

ITA 373/JODH/2019[2010-11]Status: DisposedITAT Jodhpur27 Oct 2023AY 2010-11

Section 143

…Bench “J” (AY. 2004-05), Hon’ble Delhi High Court in the case of CIT vs. La Medica (250 ITR 575), CIT vs. Hilux Automotive (P) Ltd. (23 DTR 358/183 Taxman 260), Hon’ble Punjab and Haryana High Court in the case of Mittal Belting and Machinery Stores vs. CIT (253 ITR 341). We decline in interfere with the order of the Ld. CIT(A). 4. In the result, the appeal of the Assessee is dismissed. Order pronounced in the open Court on 27th October, 2023. (SAKTIJIT DEY) (DR. B.R.R. KUMAR) VICE PRESIDENT ACCOUNTANT MEMBER Dated: 27/10/2023 PK/Ps…

MARUTI TRADEXIM PVT. LTD.,NEW DELHI vs. ITO, WARD- 16(2), NEW DELHI

ITA 3615/DEL/2018[2012-13]Status: DisposedITAT Delhi26 Apr 2023AY 2012-13

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2012-13

For Appellant: NoneFor Respondent: Shri Anil Kumar Sharma, Sr. DR

Section 131Section 143(3)Section 68

…ance Ltd. ii) McDowell & Co Limited, 154ITR148 iii) M/s Lovely Exports P. Ltd. iv) Sumati Dayal vs. CIT, 214 ITR 801 (SC) v) CIT vs. L.N. Dalmia, 207 ITR 89 (Cal) vi) Sunil Sidharatha vs. CIT, 156 ITR 507 (SC) vii) Mittal Belting and Machinery Stores vs. CIT, 253 ITR 341 (P&H) viii) CIT vs. Durga Prasad More, 82 ITR 540 (SC) ix) CIT vs. Neelkanth Ispat Udyog Pvt. Ltd. (Del) 8.5 On the basis of above discussion, the Assessing Officer held that the nature and source of share capital of Rs.4,80,00,000/- shown in the name of M/s Pushpanjali Export Pvt. Ltd. is not explained m the light of provisions of the Income Tax…

M/S SILVEX & CO.,JAIPUR vs. INCOME TAX OFFICER, WARD-7-2, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1003/JPR/2018[2006-07]Status: DisposedITAT Jaipur28 Oct 2022AY 2006-07

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri P.K. Meena (CIT)

Section 143(3)Section 69C

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR MkWa- ,l-lhrky{eh] U;kf;d lnL; ,oa Jh jkBksM deys'k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 1003/JP/2018 fu/kZkj.k o"kZ@Assessment Years : 2006-07 M/s Silvex & Company (India) cuke Income Tax Officer, Vs. Ltd., Ward-7(2), G1-35 to 37, 47 & 48 EPIP, Jaipur. Jewellery Zone, Sitapura Industrial Area, Jaipur. LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAQFS 3979 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Ass…

DCIT -32(1), MUMBAI vs. JAIN NARESH NEMICHAND HUF, MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 1367/MUM/2022[2010-11]Status: DisposedITAT Mumbai22 Aug 2022AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Bledcit – 32(1) V. Jain Naresh Nemichand Huf Room No. 702, 7Th Floor 202, Ganjawala Elagance Kautilya Bhavan Gnjawala Lane, Borivali (W) Bandra Kurla Complex Mumbai - 400092 Bandra(E), Mumbai - 400051 Pan: Aadhj5277K (Appellant) (Respondent) Assessee By : Shri Bhupendra Shah Department By Vranda U/S. Matkari

For Appellant: Shri Bhupendra Shah

Section 133(6)Section 143(1)Section 143(2)

…but these were ultimately settled in cash. Merely because a paper trail had been created, that would not by itself make the transaction genuine. It was held by Honourable Punjab & Haryana High Court in the case of Mittal Belting and Machinery Stores Vs. CIT (253 ITR 341) that if on the examination of the evidence, it is found that there was no genuine transaction between the parties, a pure paper transaction could not have entitled the assessee to claim benefit under the law. Similarly the Hon'ble Mumbai Tribunal held in the case of Balaji Textiles Industries Pvt Ltd Vs. ITO (49 LTD 177) that issue of bills by t…