(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48Supreme Court of India2019#76 most cited

What is (Central)-1 v. NRA Iron & Steel (P) Ltd. authority for?

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

696

judgments rely on this decision, according to BharatTax’s citation analysis of 371,886 Indian tax judgments — from 2011 to 2026.

Also referred to as

NRA Iron & Steel · (Central)-1 v. NRA Iron & Steel · Section 68 · cash credit · share capital · share application money · unexplained loan · onus of proof · creditworthiness · genuineness of transaction · paper company · shell company · accommodation entries

Issues it is cited on

Judgments citing (Central)-1 v. NRA Iron & Steel (P) Ltd.

ACIT 4(3)(1), Mumbai vs. Narayan Dalpatram Thakkar, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3619/MUM/2017[2008-09]Status: DisposedITAT Mumbai29 Oct 2025AY 2008-09

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2008-09 Assistant Commissioner Of Vs Narayan Dalpatram Income-Tax - 4(3)(1), Thakkar Mumbai Abhay Bldg, 5Th Floor, Ns 9Th Rdm Jvpd Scheme, Juhu Vile Parle (W), Mumbai - 400032 [Pan: Aaipt0713F] Appellant Respondent Present For: Assessee : Shri Parag Shah, Ca Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Cit(A) – 9, Mumbai, Vide Order No. Cit(A)-9/Cir.4/529/2015-16, Dated 17.03.2016 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax-4(3)(1), U/S.143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 29.01.2016 For Ay 2008-09. 2. Grounds Taken By The Revenue Are Reproduced As Under: “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Directing The Ao To Delete The Addition Made Towards Unexplained Unsecured Loan Of Rs.65,00,000/- U/S.68 Of The I.T. Act.

For Appellant: Shri Parag Shah, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(3)Section 148Section 68Section 69C

…lpatram Thakkar AY 2008-09 of his search to taint the transactions of unsecured loans as accommodation entries to make the addition. 4.1. Reliance placed by the ld. Sr. DR. on the judgement of Hon’ble Supreme Court in the case of NRA Iron and Steel Pvt. Ltd. 412 ITR 161 (SC) is found to be distinguishable on the facts in as much as in the said decision, ld. AO had made extensive enquiries and some of the investors were found to be non-existent. On going through the facts involved in that judgement, it is noted that in the decided case, the AO had made extensive enquiries and from that he had found that some of t…

Golden Goenka Commerce Pvt. Ltd., Kolkata vs. ACIT Circle-2(1), Jamshedpur

In the result, the appeal filed by the assessee stands allowed

ITA 11/RAN/2024[2011-12]Status: DisposedITAT Ranchi10 Oct 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

Section 131Section 143(3)Section 147Section 148Section 68

…IT vs. Lovely Exports Pvt. Ltd. (216 CTR 195) (SC) wherein it was held that if share application money is received from identified persons whose details are furnished, then the addition cannot be made in the hands of the company. b. PCIT vs. NRA Iron & Steel (412 ITR 161) (SC) – distinguished on facts as in the present case complete evidences were filed. c. CIT vs. Orissa Corporation Pvt. Ltd. (159 ITR 78) (SC) – once assessee furnishes basic evidences, onus shifts to department. I.T.A. No.11/Ran/2024 Golden Goenka Commerce Pvt. Ltd. 5.2 The ld. AR further submitted that in the case of the assessee for the asses…