CIT v. Daulatram Rawatmull

53 ITR 574Supreme Court of India1964#1178 most cited

What is CIT v. Daulatram Rawatmull authority for?

Additions to income cannot be made based merely on suspicion; concrete evidence is required to substantiate such claims by the tax authorities.

97

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2026.

Also referred to as

Daulatram Rawatmull · CIT v. Daulatram Rawatmull · Section 68 · Section 143(3) · suspicion vs evidence · addition without evidence · unexplained cash credits · unsecured loans · burden of proof · genuineness of transaction · no addition on mere suspicion · sufficiency of evidence

Sections most often in play

Section 133(6)Section 143(3)Section 68Section 142(1)Section 250Section 131Section 143(2)Section 147

Issues it is cited on

section 119(1)section 52(2)section 66penalty under section 271ebogus share capitalconstruction peon money receiptpreponderance of probabilitypenalty under section 271dtrccorpus fundsection 269t

Judgments citing CIT v. Daulatram Rawatmull

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. VAIBHAV GINNING SPINNING MILL PVT. LTD., RAJKOT

In the result, the Appeal of the Department is dismissed

ITA 826/RJT/2024[2017-18]Status: DisposedITAT Rajkot10 Apr 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपील सं./ Ita No. 826/Rjt/2024 िनधा"रण वष" / Assessment Year: (2017-18) (Physical Hearing) Dcit Vs. Vaibhav Ginning & Spinning Central Circle-2, Rajkot Mill Private Limited “Amruta Estate”, 2Nd Floor, Mg Road, National Highway – 27, Gondal Rajkot-360001 Rajkot Highway At Bhojpara, Gondal, Gujarat - 360311 Pan/Gir No.: Aadcv4397D (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Rajendra Singhal, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit.Dr सुनवाई की तारीख/Date Of Hearing : 26/02/2026 घोषणा की तारीख/Date Of Pronouncement : 10/04/2026

For Appellant: Shri Rajendra Singhal, ARFor Respondent: Shri Sanjay Punglia, CIT.DR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

…ises in the mind for the genuineness of the transaction on hand as discussed above. 10.2 However, it is the settled law, a suspicion cannot take the place of the evidence as held by Hon'ble Supreme Court in the case of CIT vs. Daulat Ram Rawatmull reported in 53 ITR 574, the relevant extract reads as under. "The circumstances relied upon by Mr. Sastri do raise suspicion, but suspicion cannot take the place of evidence." 10.3 For the sake of repetition, we also note that indeed, the activity of withdrawing the cash, keeping the same as it is and redeposit the same in the bank after considerable period is very unus…

SIDDHI VINAYAK SHIKSHA PRASAR EVAM SAMAJ KALYAN SAMITI,GWALIOR vs. CIT(EXEMPTION), BHOPAL

In the result, the both the appeals ITA No

ITA 579/AGR/2025[2025-26]Status: DisposedITAT Agra20 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 12A(1)(ac)Section 80G(5)(iv)

…need to further elaborate this position, because the law as laid down in these observations is well settled, and has been adopted in the construction of s 66 of the Act. 25. This view was reiterated by the Supreme Court in CIT vs. Daulatram Rawatmull (1964) 53 ITR 574 (SC) where it was held that "if there is some evidence to support the finding recorded by the Tribunal, even if it appears to the High Court that on re-appreciation of the evidence, it might arrive at a conclusion different from that of the Tribunal the High Court has no power to interfere with the findings of the Tribunal. These decisions were ap…

SIDDHI VINAYAK SHIKSHA PRASAR EVAM SAMAJ KALYAN SAMITI ,GWALIOR vs. CIT(EXTEMPTION) , BHOPAL

In the result, the both the appeals ITA No

ITA 578/AGR/2025[2025-26]Status: DisposedITAT Agra20 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 12A(1)(ac)Section 80G(5)(iv)

…need to further elaborate this position, because the law as laid down in these observations is well settled, and has been adopted in the construction of s 66 of the Act. 25. This view was reiterated by the Supreme Court in CIT vs. Daulatram Rawatmull (1964) 53 ITR 574 (SC) where it was held that "if there is some evidence to support the finding recorded by the Tribunal, even if it appears to the High Court that on re-appreciation of the evidence, it might arrive at a conclusion different from that of the Tribunal the High Court has no power to interfere with the findings of the Tribunal. These decisions were ap…

SHRI ACHLESHWAR MAHADEVJI JI SARVJANIK NIYAS,GWALIOR vs. CIT(E), BHOPAL

In the result, the appeal is allowed for statistical purposes

ITA 417/AGR/2025[2025-26]Status: DisposedITAT Agra16 Feb 2026AY 2025-26

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year : 2025-26 Shri Achleshwar Mahadev Ji V Cit (Exemption) Sarvajanik Nyas, Sanatan Bhopal Dharm Mandir Road Gwalior- 474 001 Pan : Aahts1225J (Appellant) (Respondent)

Section 80GSection 80G(5)(iii)

…need to further elaborate this position, because the law as laid down in these observations is well settled, and has been adopted in the construction of s 66 of the Act. 25. This view was reiterated by the Supreme Court in CIT vs. Daulatram Rawatmull (1964) 53 ITR 574 (SC) where it was held that "if there is some evidence to support the finding recorded by the Tribunal, even if it appears to the High Court that on re-appreciation of the evidence, it might arrive at a conclusion different from that of the Tribunal the High Court has no power to interfere with the findings of the Tribunal. These decisions were ap…

WESTCOURT HOSPITALITY PVT LTD,NEW DELHI vs. DCIT, CIRCLE-25(1), DELHI

In the result appeal of the assessee is allowed

ITA 3351/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

…any evidence showing that in fact, appellant has given cash in lieu of unsecured loan taken, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of Daulatram Rawatmull, (1964) 53 ITR 574. 20. On the issue of discharge the onus of establishing the creditworthiness of the loan creditor, the Hon'ble Delhi High court in the case of Mod. Creations (P.) Ltd. v. ITO reported in [2013] 354 ITR 282, has held as under: "It will have to be kept in mind that Section 68 of the I.T. Act only sets up a presumption against the Assessee whenever u…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-25(1), NEW DELHI, NEW DELHI vs. WESTCOURT HOSPITALITY PRIVATE LIMITED, NEW DELHI

In the result appeal of the assessee is allowed

ITA 3294/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

…any evidence showing that in fact, appellant has given cash in lieu of unsecured loan taken, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of Daulatram Rawatmull, (1964) 53 ITR 574. 20. On the issue of discharge the onus of establishing the creditworthiness of the loan creditor, the Hon'ble Delhi High court in the case of Mod. Creations (P.) Ltd. v. ITO reported in [2013] 354 ITR 282, has held as under: "It will have to be kept in mind that Section 68 of the I.T. Act only sets up a presumption against the Assessee whenever u…

NIDHI RANI,PANIPAT vs. INCOME TAX OFFICE, WARD-1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

ITA 3323/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] Smt. Nidhi Rani Vs Ito 1361, Sector-25, Part-Ii Ward-1, Panipat, Haryana-132103 Panipat Pan-Arrpr9400P Appellant Respondent Appellant By Dr. Rakesh Gupta, Adv. Shri Somil Agarwal, Adv. & Shri Saksham Agarwal, Ca Respondent By Shri Shyam Manohar Singh, Sr.Dr Date Of Hearing 24.09.2025 Date Of Pronouncement 19.12.2025 Order

Section 142(1)Section 143Section 143(2)Section 143(3)Section 234ASection 250Section 68

…any evidence showing that in fact, appellant has given cash in lieu of unsecured loan taken, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of Daulatram Rawatmull, (1964) 53 ITR 574. 21. On the issue of discharge the onus of establishing the creditworthiness of the loan creditor, the Hon'ble Delhi High court in the case of Mod. Creations (P.) Ltd. v. ITO reported in [2013] 354 ITR 282, has held as under: "It will have to be kept in mind that Section 68 of the I.T. Act only sets up a presumption against the Assessee whenever u…

SURENDER SINGH SANGWAN,DELHI vs. ITO WARD-4, SONIPAT

In the result, appeal of the assessee is partly allowed

ITA 1639/DEL/2025[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal[Assessment Year : 2016-17] Surender Singh Sangwan Vs Ito C/O-Kapil Goel, Advocate Ward-4, Aayakar F-26/124, Sector-7 Bhawan, Sonepat, Rohini, Delhi-110085 Haryana Pan-Bqsps5616M Appellant Respondent Appellant By Dr. Kapil Goel Respondent By Shri Manish Gupta, Sr. Dr Date Of Hearing 18.09.2025 Date Of Pronouncement 12.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 06.12.2024 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Rohtak/10489/2018-19 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 27.12.2018 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That Assessee E-Filed His Return Of Income, Declaring Total Income At Inr 7,00,190/-. The Case Was Selected For Scrutiny Through Cass & Notice U/S 143(2) Was Issued To The Assessee On 07.07.2017 & Duly Served Upon The Assessee. Thereafter, Notices U/S 142(1) Of The Act Alongwith Questionnaire Were Issued On 25.04.2018. In Response Assessee Has Filed Reply Which Were Considered By The Ao & The Assessment Order Was Passed U/S 143(3) Of The Act Dated 27.12.2018 Wherein The Total Income Stood Assessed At Inr 1,12,94,400/- By Making Addition U/S 68 Of The Act Towards Unsecured Loans Of Inr 1,05,00,000/- Received During The Year Under Appeal. Besides Disallowance Of Rs. 94,210/- Out Of Various Expenses Claimed Is Also Made.

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

…any evidence showing that in fact, appellant has given cash in lieu of unsecured loan taken, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of Daulatram Rawatmull, (1964) 53 ITR 574.” 16. The judgements referred by Ld.AR of NRA Iron and Steel is distinguishable on facts in that case, detailed enquiry was made by the AO and assessee has failed to file any details before the lower authorities however, in the instant case, the assessee has already filed all the relevant details to discharge the burden casted upon it u/s 68 of t…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), KOLKATA, KOLKATA vs. RAJSHRI IRON INDUSTRIES PRIVATE LIMITED, KOLKATA

In the result, both the appeals of the Revenue are dismissed

ITA 2388/KOL/2024[2013]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

…e may refer to decisions in Dhakeswari Cotton Mills Ltd. v. CIT 26 ITR 775 (SC), Lalchand Bhagat Ambica Ram v. CIT 37 ITR 288 (SC), CIT v. East Coast Commercial Co. Ltd.63 ITR 449 (SC) and Anil Tibrewala v. ITO(2004) 1 SOT 90 (Mum); CIT v. Daulatram Rawatmull 53 ITR 574 (SC); Umacharan Shaw & Bros. v. CIT 37 ITR 271 (SC); Pr. CIT v. Ajay Surendrabhai Patel(2016) 69 taxmann.com 309 (Guj.). 24. It is further submitted that the findings of the AO in the concluding portion of the order of assessment (Page-28) was as follows: ……there is no iota of evidence in assessee's submission that it has no nexus with the Majee g…

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(1), KOLKATA, KOLKATA vs. RAJSHRI IRON INDUSTRIES PRIVATE LIMITED, KOLKATA

In the result, both the appeals of the Revenue are dismissed

ITA 2385/KOL/2024[2018]Status: DisposedITAT Kolkata21 Nov 2025

Bench: Shri Rajesh Kumar, Am & Shrisonjoy Sarma, Jm

For Appellant: Shri Soumitra Choudhury, ARFor Respondent: S/Shri Praveen Kishore &
Section 147Section 148Section 148ASection 69C

…e may refer to decisions in Dhakeswari Cotton Mills Ltd. v. CIT 26 ITR 775 (SC), Lalchand Bhagat Ambica Ram v. CIT 37 ITR 288 (SC), CIT v. East Coast Commercial Co. Ltd.63 ITR 449 (SC) and Anil Tibrewala v. ITO(2004) 1 SOT 90 (Mum); CIT v. Daulatram Rawatmull 53 ITR 574 (SC); Umacharan Shaw & Bros. v. CIT 37 ITR 271 (SC); Pr. CIT v. Ajay Surendrabhai Patel(2016) 69 taxmann.com 309 (Guj.). 24. It is further submitted that the findings of the AO in the concluding portion of the order of assessment (Page-28) was as follows: ……there is no iota of evidence in assessee's submission that it has no nexus with the Majee g…

JSM OILFIELDS SERVICES PVT. LTD,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX , NEW DELHI

In the result, appeal of the assessee is allowed

ITA 4093/DEL/2024[2013-14]Status: DisposedITAT Delhi21 Nov 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2013-14] Jsm Oilfields Services Pvt.Ltd., Vs Dcit, Farm No.14, 8Th Avenue, Radhey Circle-13(1), Mohan Drive, Gadaipur, New Delhi New Delhi-110017. Pan-Aabcj1500C Appellant Respondent Appellant By Shri Anil Jain, Adv. Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 26.08.2025 Date Of Pronouncement 21.11.2025

Section 131Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 68

…f any evidence showing that in fact, appellant has given cash in lieu of call money received, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of Daulatram Rawatmull (1964) 53 ITR 574 (SC). 13. Further, the Hon'ble Delhi High Court in the case of CIT vs. Vrindavan Farms Pvt. Ltd. etc. in ITA. No.71 of 2015 dated 12th August, 2015 held as under : "The sole basis for the Revenue to doubt their creditworthiness was the low income as reflected in their return of income. lt was observed by the ITAT that the Assessing Officer had n…

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BENGALURU

ITA 940/BANG/2025[2021-22]Status: DisposedITAT Bangalore13 Nov 2025AY 2021-22
For Appellant: Shri M.V Prasad, CA & Shri KS Rajendra KumarFor Respondent: Shri Muthu Shankar, CIT &
Section 12ASection 143(3)Section 153ASection 153BSection 25Section 250Section 8

…in it was held\nthat suspicion cannot take the place of proof and conclusion based on surmises\nand conjectures is not tenable. The appellant also places reliance on similar\ndecision of Hon’ble Supreme Court in the case of CIT Vs. Daulatram Rawatmull\n[1964] 53 ITR 574 (SC) (Copy submitted at Page Nos.45 to 49 of PB-3).\n69. The ratio laid down by the Hon’ble Apex court in the afore mentioned\ncases is squarely applicable to the facts of the appellant’s case. The appellant\nsubmits that the finding of the AO regarding the diversion of the funds of the\ntrust for the individual benefit of the trustees in violatio…

SRI SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

ITA 939/BANG/2025[2020-21]Status: DisposedITAT Bangalore13 Nov 2025AY 2020-21
For Appellant: \nShri M.V Prasad, CA & Shri KS Rajendra KumarFor Respondent: \nShri Muthu Shankar, CIT &
Section 12ASection 143(3)Section 153ASection 153BSection 25Section 250Section 8

…in it was held\nthat suspicion cannot take the place of proof and conclusion based on surmises\nand conjectures is not tenable. The appellant also places reliance on similar\ndecision of Hon’ble Supreme Court in the case of CIT Vs. Daulatram Rawatmull\n[1964] 53 ITR 574 (SC) (Copy submitted at Page Nos.45 to 49 of PB-3).\n\n69. The ratio laid down by the Hon’ble Apex court in the afore mentioned\ncases is squarely applicable to the facts of the appellant’s case. The appellant\nsubmits that the finding of the AO regarding the diversion of the funds of the\ntrust for the individual benefit of the trustees in violat…

INCOME TAX OFFICER WARD 52(1) NEW DELHI, NEW DELHI vs. M/S NOVEL INFRATECH, NEW DELHI

In the result appeal of the revenue is dismissed

ITA 188/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Sudhir Kumarito, Vs. M/S. Novel Infratech, Ward-52(1), Flat No. 915, Indra Prakash New Delhi Building, 21, Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aajfn0187A

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131(1)(d)Section 133(6)Section 143(3)Section 68

…f any evidence showing that in fact, assessee has given cash in lieu of unsecured loan taken, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of DaulatramRawatmull, (1964) 53 ITR 574. 51. The Assessing Officer has also alleged that the partner of the firm of the assessee was required to appear before him but he refused to appear by stating that there is no proceedings pending in respect of him. Thus, Assessing Officer contended that the assessee had made deliberate attempt to not cooperate in the proceedings. The mere non appe…

ASSISTANT COMMISSIONER OF INCOME TAX, JALANDHAR vs. M/S JASDEEP KAUR CHADHA, JALANDHAR

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

ITA 359/ASR/2025[2018-19]Status: DisposedITAT Amritsar22 Aug 2025AY 2018-19

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 143(3)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH. KHETTRA MOHAN ROY, ACCOUNTANT MEMBER I.T.A. No. 250/Asr/2025 Assessment Year: 2018-19 Jasdeep Kaur Chadha, Vs. DCIT, Circle-4, Jalandhar, 5, Defence Colony, Jalandhar. Jalandhar City, Jalandhar. [PAN: AAMFJ9095L] (Respondent) (Appellant) I.T.A. No. 359/Asr/2025 Assessment Year: 2018-19 Asstt. Commissioner of Income Vs. Jasdeep Kaur Chadha, Tax, Jalandhar, 5, Defence Jalandhar. Colony, Jalandhar City, Jalandhar. [PAN: AAMFJ9095L] (Respondent) (Appellant) Appellant by Sh. Sudhir Sehgal, Adv.…

BHAI DAYA SINGH JI BHAI HIMMAT SINGH JI NISHKAM SATSANG SABHA THROUGH ITS MANAGING TRUSTEE,LUDHIANA, PUNJAB vs. THE COMMISSIONER OF INCOME-TAX (EXEMPTIONS), CHANDIGARH

Accordingly. 22. In the combined result, both appeals (ITA No.728 & 732/SRT/2023) are allowed for statistical purposes in above terms

ITA 258/ASR/2025[2025-2026]Status: DisposedITAT Amritsar22 Aug 2025AY 2025-2026

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 80GSection 80G(5)Section 80G(5)(iii)

…aid down in these observations is well settled, and has been adopted in the construction of section 66 of the I.T.A. No. 257 & 258/Asr/2025 Assessment Year: N/A 12 Act." 25. This view was reiterated by the Supreme Court in CIT v. Daulatram Rawatmull [1964] 53 ITR 574 where it was held that "if there is some evidence to support the finding recorded by the Tribunal, even if it appears to the High Court that on re-appreciation of the evidence, it might arrive at a conclusion different from that of the Tribunal" the High Court has no power to interfere with the findings of the Tribunal. These decisions were applie…

BHAI DAYA SINGH JI BHAI DHARAM SINGH JI NISHKAM SATSANG SABHA,LUDHIANA vs. THE COMMISSIONER OF INCOME-TAX (EXEMPTIONS), CHANDIGARH

Accordingly. 22. In the combined result, both appeals (ITA No.728 & 732/SRT/2023) are allowed for statistical purposes in above terms

ITA 257/ASR/2025[2025-2026]Status: DisposedITAT Amritsar22 Aug 2025AY 2025-2026

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 80GSection 80G(5)Section 80G(5)(iii)

…aid down in these observations is well settled, and has been adopted in the construction of section 66 of the I.T.A. No. 257 & 258/Asr/2025 Assessment Year: N/A 12 Act." 25. This view was reiterated by the Supreme Court in CIT v. Daulatram Rawatmull [1964] 53 ITR 574 where it was held that "if there is some evidence to support the finding recorded by the Tribunal, even if it appears to the High Court that on re-appreciation of the evidence, it might arrive at a conclusion different from that of the Tribunal" the High Court has no power to interfere with the findings of the Tribunal. These decisions were applie…

JASDEEP KAUR CHADHA-JALANDHAR,PUNJAB vs. JAO THE DCIT CIRCLE-4 JALANDHAR, PUNJAB

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

ITA 250/ASR/2025[2018-2019]Status: DisposedITAT Amritsar22 Aug 2025AY 2018-2019

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 143(3)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR. BEFORE SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH. KHETTRA MOHAN ROY, ACCOUNTANT MEMBER I.T.A. No. 250/Asr/2025 Assessment Year: 2018-19 Jasdeep Kaur Chadha, Vs. DCIT, Circle-4, Jalandhar, 5, Defence Colony, Jalandhar. Jalandhar City, Jalandhar. [PAN: AAMFJ9095L] (Respondent) (Appellant) I.T.A. No. 359/Asr/2025 Assessment Year: 2018-19 Asstt. Commissioner of Income Vs. Jasdeep Kaur Chadha, Tax, Jalandhar, 5, Defence Jalandhar. Colony, Jalandhar City, Jalandhar. [PAN: AAMFJ9095L] (Respondent) (Appellant) Appellant by Sh. Sudhir Sehgal, Adv.…

INCOME TAX OFFICER WARD-16(3), DELHI ITO vs. MANSAROVER EXIM PVT. LTD. , DELHI

ITA 1275/DEL/2024[2012-13]Status: DisposedITAT Delhi30 Jul 2025AY 2012-13

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2012-13] Ito, Vs Mansarover Exim Pvt.Ltd., Ward-16(3), 2, First Floor, Pocket-H-34, Delhi Plot No.35, Sector-3, Rohini, New Delhi-110085. Pan-Aaecm9328A Appellant Respondent Revenue By Ms. Amisha S.Gupta, Cit Dr Assessee By Shri Rohit Jain, Adv., Shri Shourya Jain, Ca & Shri Deepesh Jain, Adv. Date Of Hearing 06.05.2025 Date Of Pronouncement 30.07.2025 Order

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

…any evidence showing that in fact, appellant has given cash in lieu of unsecured loan taken, merely on the basis of suspicion, no addition can be made for which reliance is placed on decision of Hon'ble Supreme court in the case of Daulatram Rawatmull (1964) 53 ITR 574 (SC). 17. The Co-ordinate Bench of ITAT, Delhi in the case of ITO Vs. Alpha Contech Pvt. Ltd. in ITA No.3351/Del/2016 vide order dated 28.07.2023 while deleting the additions made by AO by alleging the loan creditors as bogus, has held as under: 7. On careful consideration of above rival submission, first of all, we note that the Assessing Office…

INCOME TAX OFFICER, DELHI vs. AKASH DEEP SETHI, DELHI

In the result, the appeal filed by the Revenue is dismissed and at the same time, the cross objections filed by the assessee are also dismissed

ITA 4973/DEL/2024[2021-22]Status: DisposedITAT Delhi16 Jul 2025AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri S. Rifaur Rahmanincome Tax Officer, Vs. Akash Deep Sethi, Delhi. B-236, Derawal Nagar, Model Town, Delhi – 110 009. (Pan : Abyps8933P) Co No.26/Del/2025 (In Ita No.4973/Del/2024) (Assessment Year: 2021-22) Akash Deep Sethi, Vs. Income Tax Officer, B-236, Derawal Nagar, Delhi. Model Town, Delhi – 110 009. (Pan : Abyps8933P) (Appellant) (Respondent) Assessee By : Shri Ved Jain, Advocate Shri Aman Garg, Ca Ms. Kirti, Ca Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 27.05.2025 Date Of Order : 16.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133(6)Section 139Section 142(1)Section 143(2)Section 143(3)Section 44A

…lanation to hold that it was income. If, however, the evidence was unconvincing, then such rejection could be made. The Department cannot by merely rejecting good explanation unreasonably, convert good proof into no proof. In CIT v. Daulatram Rawatmull [1964] 53 ITR 574 (SC), the principles governing reference under section66 of the 1922 Act, similar to section 256 of 1961 Act were discussed and it was held that the High Court has no power under section 66(2) of the Indian Income-tax Act, 1922, which is in parimateria with section256(2) of the Act, to call upon the Appellate Tribunal to state a case, if there was…

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