How many judgments cite CIT v. Kulwant Rai?

142 judgments on BharatTax cite CIT v. Kulwant Rai (291 ITR 36), spanning 2015 to 2026.

Which sections of the Income Tax Act does CIT v. Kulwant Rai come up under?

It is most often cited in judgments turning on Section 143(3), Section 69A, Section 115BBE, Section 68, Section 69, Section 132.

CIT v. Kulwant Rai

291 ITR 36High Court2007#713 most cited

What is CIT v. Kulwant Rai authority for?

An assessee can explain cash deposits, including those in bank accounts, by demonstrating sufficient cash balance as per their books of account or from previous cash withdrawals. If the explanation is substantiated and the revenue cannot prove otherwise, the source of deposits is deemed proved, precluding additions under Section 68.

142

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Kulwant Rai · Section 68 · Section 115BBE · cash deposits explanation · source of cash deposits · cash book · previous cash withdrawals · unexplained money · onus of proof · Delhi High Court

Also reported as

163 Taxmann 585210 CTR 380

Sections most often in play

Section 143(3)Section 69A Section 115BBE Section 68 Section 69 Section 132 Section 153A Section 142(1)

Read the full judgment

Issues it is cited on

section 158bc circle rate preponderance of probability section 2(47)interest u/s 234a lack of enquiry section 69b section 158b section 158 section 48 dumb documents section 115bb

Judgments citing CIT v. Kulwant Rai

Shri Hareshkumar Jayantilal Mahadevwala HUF, Surat vs. Income Tax Officer, Ward - 1(3)(1), Surat

In the result, ground No.1 of the appeal is partly allowed

ITA 248/SRT/2023[2017-18]Status: DisposedITAT Surat30 Nov 2023AY 2017-18

Bench: Shri Pawan Singh(Hybrid Hearing) Hareshkumar Jayantilal I.T.O., Mahadevwala Huf, Ward-1(3)(1), Vs. 145, Sarjan Society, Parlepoint, Surat. Athwalines, Surat, Gujarat-395001. Pan No. Aaahh 8541 R Appellant/ Assessee Respondent/ Revenue

Section 115BSection 142(1)Section 143(2)Section 254(1)Section 68

…UF Vs ITO of Section 115BBE of the Act. To support such submission that the addition on account of unexplained cash credit is not warranted, relied on the following decisions: (1) Narendra G. Goradia HUF Vs CIT (1998) 234 ITR 571 (Bom) (2) CIT Vs. Kulvant Rai 291 ITR 36 (Del) (3) Lakshmi Rice Mills Vs CIT (1974) 97 ITR 258 (Pat) (4) Gur Prasad Hari Das Vs CIT (1963) 47 ITR 634 (All) (5) Kanpur Steel Co. Ltd. Vs CIT (1957) 32 ITR 56 (All) (6) S.R. Venkata Ratnam Vs CIT (1980) 48 CCH 619 (Kar) (7) Vinatha Madhusdan Reddy Vs ACIT (2018) 54 CCH 151 (Mum Trib) (8) R.S. Diamond (P) Ltd. Vs ACIT (2022) 145 taxmann.com 5…

P L Steels Pvt Ltd, New Delhi vs. DCIT Circle-19(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 632/DEL/2021[2017-18]Status: DisposedITAT Delhi13 Nov 2023AY 2017-18

Bench: Dr. B. R. R. Kumarshri Yogesh Kumar Us

For Appellant: Ms. Rano Jain, AdvFor Respondent: Ms. Sapna Bhatia,CIT-DR

Section 68

…ssee, 7 P L Steels P. Ltd. there was any other purposes it is used by the assessee of these amounts. In view of above facts, the ground number 1 of the appeal of the assessee is allowed and orders of lower authorities are reversed." CIT vs. Kulwant Rai(2007) 291 ITR 36 (Delhi-HC) "16. This cash flow statement furnished by the assessee was rejected by the AO which is on the basis of suspicion that the assessee must have spent the amount for some other purposes. The orders of AO as well as CIT(A) are completely silent as to for what purpose the earlier withdrawals would have been spent. As per the cash book mainta…

Chander Lekha Vashishtha, Ghaziabad vs. ITO Ward 50(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 607/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Oct 2023AY 2017-18

Bench: SHRI CHANDRA MOHAN GARG (Judicial Member)

For Appellant: Shri P.C Yadav, AdvFor Respondent: Shri Om Prakash, Sr.DR

Section 143(3)Section 154Section 69A

…nnot be doubted or disbelieved. Therefore action of the Assessing Officer in making addition u/s. 69A of the Act may kindly be set aside. 5. Further placing reliance on the judgment of Hon’ble High Court of Delhi in the case of CIT vs. Kulwant Rai reported as 291 ITR 36 (Del.) the ld. counsel submitted that when the Assessing Officer rejecting the cash flow statement submitted by the assessee on the ground that the assessee must have spend the amount withdrawn from the bank for some other purposes and no material is on record to show that money was not available with the assessee then addition cannot be held as s…

ACIT, Circle- 7(2), New Delhi vs. Dsl Properties Pvt. Ltd., New Delhi

Appeal of the Revenue is allowed for statistical purposes

ITA 5946/DEL/2017[2014-15]Status: DisposedITAT Delhi13 Oct 2023AY 2014-15

Section 131Section 132Section 143(3)

…declared in sync with registered sale agreement and the consideration referred in document no.54 to affirms the declared sale consideration. The Learned Counsel referred to judgment rendered by Hon’ble Delhi High Court in the case of CIT vs. Shri Kulwant Rai 291 ITR 36(Delhi) to contend that assessment cannot be made on the basis of imagination and guesswork, which has been done by the AO in the instant case. The Learned Counsel thus submitted that the action of the CIT(A) cannot be faulted and no interference therewith is called for. 8. We have carefully considered the rival submissions and perused the assessm…

Narendra Kumar Gupta, New Delhi vs. DCIT Central Circle-20, New Delhi

In the result, assessee’s appeal stands allowed

ITA 1186/DEL/2023[2019-20]Status: DisposedITAT Delhi11 Oct 2023AY 2019-20

Bench: SHRI SHAMIM YAHYA (Accountant Member), MS. ASTHA CHANDRA (Judicial Member)

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri Subhra Jyoti Chakraborty, CIT DR

Section 132(1)Section 143(3)Section 153ASection 153DSection 44ASection 69

…d that cash withdrawn is also put to any other use. In such circumstances, there is no reason to reject the source of cash in this regard. In this regard, we draw support from the decision of Hon’ble Delhi High Court in the case of CIT vs. Kulwant Rai (2007) 291 ITR 36 (Delhi) for the following proposition :- “16. This cash flow statement furnished by the assessee was rejected by the Assessing Officer which is on the basis of suspicion that the assessee must have spent the amount for some other purposes. The orders of the Assessing Officer as well as the Commissioner of Income-tax are completely silent as to f…

Ahluwalia Erectors & Fabricators Private Limited, Jaipur vs. ACIT, Kota

In the result, the appeal of the assessee is partly allowed as indicated hereinabove

ITA 433/JPR/2022[2017-18]Status: DisposedITAT Jaipur11 Oct 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahendra Gargieya, AdvocateFor Respondent: Shri A.S. Nehra Addl. CITa

Section 143(3)Section 234B

…indings recorded by the Tribunal are purely findings of fact—There is no reason to interfere with the same—No substantial question of law arises—CIT vs. Pradeep Shantaram Padgaonkar (1983) 143 ITR 785 (MP) relied on” 6.4. Also refer CIT vs Kulwant Rai (2007) 210 CTR 380 (Delhi) para 16- 17(DPB 17-22) Read held “Search and seizure—Block assessment—Computation of undisclosed income—Cash found during search—Assessee had withdrawn Rs. 2 lakh from bank some time back and there is no material with the Department to show that this money had been spent and was not available with the assessee—Tribunal has found that the…

Smt. Adesh Agrawal, New Delhi vs. ITO, Haldwani

In the result, the appeal of the assessee is partly allowed

ITA 3281/DEL/2017[2009-10]Status: DisposedITAT Dehradun15 Sept 2023AY 2009-10

Section 142(1)Section 143(1)Section 143(3)Section 145Section 147Section 148

…Smt. Adesh Agrawal vs. ITO power and possession of assessee, therefore, no presumption u/s 292C drawn against assessee. Further the ld. AR had rightly placed reliance on the decision of Hon’ble Delhi High Court in the case of CIT vs Kulwant Rai reported in 291 ITR 36 (Del) , wherein, it was held as under:- 12. Coming to the facts of the present case with regard to the addition of Rs. 17,00,892 made by the Assessing Officer as undisclosed income of the assessee for the block period, we may refer to the findings of the Tribunal on this point and the relevant portion reads as under :— "On consideration of the mat…

Sushil Kumar Jhabak, Bikaner vs. NFAC, Delhi / ITO, Ward-2, Bikaner

In the result, the appeal of the assessee is allowed

ITA 10/JODH/2022[2017-18]Status: DisposedITAT Jodhpur04 Aug 2023AY 2017-18

Bench: The Ao With All Supporting Evidence But Ld. Ao Ignored While Relevant Facts So The Addition Made By Ao For Treating The Cash Deposit Rs. 5,50,000/- Unexplained & Charged Tax At A Special Rate Which Was Not Ought To So It Is Deserve To Be Deleted. 2. On The Fact & Circumstances Of The Case Ld. Ao Has Erred In Charging Interest U/S 234B & 234C. 3.The Appellant Prays For Justice & Relief. 4. The Appellant May Please Be Permitted To Raise Any Additional Or Alternative Ground Sat Or Before The Hearing.”

Section 143Section 234BSection 69A

…of these amounts. In view of above facts, the ground number 1 of the appeal of the assessee is allowed and orders of lower authorities are reversed. One can also place his reliance on the decision of Ld. Delhi High Court in the case of CIT vs Kulwant rai in 291 ITR 36 wherein the honourable Delhi High Court has held as under:- “ This cash flow statement furnished by the assessee was rejected by the AO which is on the basis of suspicion that the assessee must have spent the amount for some other purposes. The orders of AO as well as CIT(A) are completely silent as to for what purpose the earlier withdrawals woul…

Parshavnath Builders, Jaipur vs. PCIT, Udaipur

In the result, the appeal of the assessee is dismissed

ITA 284/JPR/2022[2017-18]Status: DisposedITAT Jaipur20 Jun 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri MahendraGargieya ,Adv. &For Respondent: Shri James Kurian, CIT

Section 143(3)Section 263

…dditions—Findings recorded by the Tribunal are purely findings of fact—There is no reason to interfere with the same—No substantial question of law arises—CIT vs. Pradeep Shantaram Padgaonkar (1983) 143 ITR 785 (MP) relied on” 7.2 In CIT vs Kulwant Rai (2007) 210 CTR 380 ( Delhi) para 16-17 Read held “Search and seizure—Block assessment—Computation of undisclosed income—Cash found during search—Assessee had withdrawn Rs. 2 lakh from bank some time back and there is no material with the Department to show that this money had been spent and was not available with the assessee—Tribunal has found that the withdrawals…

Arjunsinh Harisinh Thakor, Surat vs. Income Tax Officer, Bardoli

In the result, grounds No

ITA 245/SRT/2021[2017-18]Status: DisposedITAT Surat15 Jun 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Arjunsinh Harisinh Thakor, I.T.O., 1 Thakor Niwas, Zanda Chowk, Ward-1, Vs. Tarasadi Road, Kosamba, Bardoli. Surat-394120. Pan No. Aabpt 1270 G Appellant/ Assessee Respondent/ Revenue

Section 115BSection 254(1)Section 68

…(Bom) (2) Lakshmi Rice Mills Vs CIT (1974) 97 ITR 258 (Pat) (3) Gur Prasad Hari Das Vs CIT (1963) 47 ITR 634 (All) (4) Kanpur Steel Co. Ltd. Vs CIT (1957) 32 ITR 56 (All) (5) Sri Sri Nilkantha Narayan Singh Vs CIT (1951) 20 ITR 8 (Pat) (6) CIT Vs Kulvant Rai 291 ITR 36 (Del) (7) S.R. Venkata Ratnam Vs CIT (1980) 48 CCH 0619 (Kar) (8) Vinatha Madhusudan Reddy Vs ACIT (2018) 54 CCH 0151 (Mum Trib) (9) R.S. Diamonds India (P) Ltd. Vs ACIT (2022) 145 taxmann.com 545 (Mum-Trib) 8 Arjunsinh Harisinh Thakor Vs ITO (10) ACIT Vs Baldev Raj Charia & Ors. 121 TTJ 366 (Del-Trib) (11) Om Prakash Nahar Vs ITO (2022) 135 taxm…

Array Land Developers P. Ltd, Chennai vs. DCIT, Central Circle 2(2), Chennai

The appeals stand allowed

ITA 381/CHNY/2022[2016-17]Status: DisposedITAT Chennai09 Jun 2023AY 2016-17

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Venkata Raman (C.A)- Ld.ARFor Respondent: Shri M.Rajan (CIT) – Ld. DR

Section 142(1)Section 143

…आयकर अपीलीय अिधकरण ‘सी’ "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI माननीय +ी वी. दुगा1 राव, "ाियक सद2 एवं माननीय +ी मनोज कुमार अ7वाल ,लेखा सद2 के सम9। BEFORE HON’BLE SHRI V. DURGA RAO, JUDICIAL MEMBER AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.379/Chny/2022 (िनधा1रण वष1 / Assessment Year: 2015-16) & आयकर अपील सं./ ITA No.381/Chny/2022 (िनधा1रण वष1 / Assessment Year: 2016-17) & आयकर अपील सं./ ITA No.380/Chny/2022 (िनधा1रण वष1 / Assessment Year: 2017-18) M/s. Array Land Developers Pvt. Ltd. DCIT बनाम Old No.19 & 20, New No.38/12, Central Circle-2(2) Venkatarman Str…

Array Land Developers P. Ltd, Chennai vs. DCIT, Central Circle- 2(2), Chennai

The appeals stand allowed

ITA 380/CHNY/2022[2017-18]Status: DisposedITAT Chennai09 Jun 2023AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Venkata Raman (C.A)- Ld.ARFor Respondent: Shri M.Rajan (CIT) – Ld. DR

Section 142(1)Section 143

Array Land Developers Private Limited, Chennai vs. DCIT Central Circle 2(2), Chennai

The appeals stand allowed

ITA 379/CHNY/2022[2015-2016]Status: DisposedITAT Chennai09 Jun 2023AY 2015-2016

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Venkata Raman (C.A)- Ld.ARFor Respondent: Shri M.Rajan (CIT) – Ld. DR

Section 142(1)Section 143

Clayton Charles Pinto, Mumbai vs. Int Tax Ward 3(3)(1), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 102/MUM/2023[2017-18]Status: DisposedITAT Mumbai09 Jun 2023AY 2017-18

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleclayton Charles Pinto Mumbai. V. Int Tax Ward 3(3)(1) Mumbai. Air India Building, Mumbai- 400021 303 Palm Beach Apartments, 31 J P Road, Andheri West Mumbai- 400061

Section 133(6)Section 142(1)Section 143(1)Section 143(2)

…emonstrate that the amount in question has been used by the assessee for any other purpose. In my view addition is made on inferences and presumptions which is bad in law. Delhi ITAT” xvi. Similar view was held in the case of Kulwant Rai [2007] 163 Taxman 585/291 ITR 36 cash flow statement must be considered. Page No. | 18 CLAYTON CHARLES PINTO xvii. Merely because the entire cash holding of HDNS as on 8.11.2016 was not deposited immediately or at once cannot by itself lead to the conclusion that the assessee did not have the corresponding cash. It can merely lead to suspicion but based on such suspicion no addi…

Shri Hemant Pandya, Indore vs. The ITO 3(2), Bhopal

ITA 173/IND/2022[2009-10]Status: DisposedITAT Indore22 May 2023AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2009-10 Shri Hemant Pandya, Ito-3(2), बनाम/ 139, Prabhu Nagar, Bhopal Indore Vs. (Appellant / Assessee) (Respondent / Revenue) Pan: Ajgpp 7486 G Assessee By Shri V.N. Dubey, Shri Ibrahim Kannodwala, Adv. & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 02.03.2023 Date Of Pronouncement 22.05.2023

Section 143(2)Section 143(3)Section 147Section 148Section 69

…1 and 2 to concern themselves with what the assessee did with that money, i.e., whether he had kept the same in his house or utilised the services of a bank by depositing the same." 22. Similarly, the Hon'ble Delhi High Court in the case of CIT vs Kulwant Rai 291 ITR 36 (Del), has observed as under:- "The orders of Assessing Officer as well as Commissioner of Income Tax are completely silent as to for what purpose the earlier withdrawals would have been spent. As per the cash book maintained by the assessed, a sum of Rs. 10,000/- was being spent for household expenses every month and the assessed has withdrawn fr…

Ballu Singh, Gurgaon vs. ITO Ward -65(5), New Delhi

In the result, the appeal of the assessee is allowed

ITA 800/DEL/2020[2009-10]Status: DisposedITAT Delhi15 May 2023AY 2009-10

Bench: Shri Kul Bharat

Section 133(6)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 44ASection 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “SMC” BENCH: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER ITA No.799 & 800/Del/2020 [Assessment Year : 2008-09 & 2009-10] Ballu Singh, vs ITO, H.No.415, Sec-22, Gurgaon, Ward-65(5), Haryana-122016. New Delhi. PAN-ARBPS7573G APPELLANT RESPONDENT Appellant by Shri N.K.Ishwar & Shri Anjani Kumar Singh, Adv. Respondent by Shri Om Parkash, Sr. DR Date of Hearing 27.04.2023 Date of Pronouncement 15.05.2023 ORDER PER KUL BHARAT, JM : These two appeals filed by the assessee for the assessment years 2008- 09 and 2009-10 are directed against the different orders of Ld. CIT(A…

Ballu Singh, Gurgaon vs. ITO Ward -65(5), New Delhi

In the result, the appeal of the assessee is allowed

ITA 799/DEL/2020[2008-09]Status: DisposedITAT Delhi15 May 2023AY 2008-09

Bench: Shri Kul Bharat

Section 133(6)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 44ASection 69A

Thakordas Parekh & Sons, Na vs. Arivs.Income Tax Officer, Ward-5, Navsari

In the result, ground No. 2 & 3

ITA 167/SRT/2022[2017-18]Status: DisposedITAT Surat30 Mar 2023AY 2017-18

Bench: Shri Pawan Singhआ.अ.सं./Ita No.167/Srt/2022 (Ay 2017-18) (Hearing In Physical Court) Thakordas Parekh & Sons Income Tax Officer, Ward-5, Bazar Street, Chikhli, Navsari, 204, 2Nd Floor, Vs Navsari-396530 Income Tax Office, Pan No: Aabft 4593 J Charpool, Awabaug, Navsari-396445 अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By Shri Rasesh Shah, C.A राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing 05.01.2023 उ"घोषणा क" तार"ख/Date Of 30.03.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Nfac/Ld.Cit(A)”] Dated 23.03.2022 For Assessment Year 2017-18, Which In Turn Arises From The Addition Made By The Income Tax Officer, Ward-5, Navsari / Assessing Officer In Assessment Order Passed Under Section 144 R.W.S143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 30.12.2019. The Assessee Has Raised The Following Grounds Of Appeal:- “1. On The Facts & In The Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Thakordas Parekh & Sons Of Assessing Officer In Rejecting The Books Of Accounts U/S 145(3) Of The Act.

Section 115BSection 144Section 145(3)Section 254(1)Section 68

…R 571 (Bom)  Lakshmi Rice Mills vs. CIT (1974) 97 ITR 258 (Pat)  Gur Prasad Hari Das vs. CIT (1963) 47 ITR 634 (All)  Kanpur Steel Co. Ltd. vs. CIT (1957) 32 ITR 56 (All)  Sri Sri Nilkantha Narayan Singh vs. CIT (1951) 20 ITR 8 (Pat)  CIT vs. Kulvant Rai 291 ITR 36 (Del)  Atish Singla Vs Income Tax Officer [ITA No.1185/Del/2021 dated 06.04.2022  Agson Global Pvt. Ltd. vs. ACIT 115 taxmann.com 342 (Del.Trib)  Asst. Commissioner of Income-tax Vs M/s Hirapanna Jewellers [ITA No.253/Viz/2020 dated 12.05.2021] [128 taxmann.com 291 (Viz.Trib.) 9. On taxing such addition under 115BBE, the Ld. AR for the assessee…

Pawan Meena, Plot No.91 vs. ITO, WD2(5), Jaipur

In the result, the appeal of the assessee is allowed

ITA 410/JPR/2022[2017-2018]Status: DisposedITAT Jaipur16 Mar 2023AY 2017-2018

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Ashish Khandelwal (C.A.)For Respondent: Ms Monisha Choudhary (Addl. CIT)

Section 143(2)Section 143(3)Section 69A

…assessee, there was any other purposes it is used by the assessee of these amounts. In view of above facts, the ground number 1 of the appeal of the assessee is allowed and orders of lower authorities are reversed.[Emphasis Supplied ] In CIT vs Kulwant rai [ 291 ITR 36] , the Hon’ble Delhi High Court held as under :- “ This cash flow statement furnished by the assessee was rejected by the AO which is on the basis of suspicion that the assessee must have spent the amount for some other purposes. The orders of AO as well as CIT(A) are completely silent as to for what purpose the earlier withdrawals would have been…

Mamta Gupta, Faridabad vs. ITO, OSD-1, Faridabad

In the result appeal of the assessee is partly allowed

ITA 1692/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Mar 2023AY 2017-18

Bench: Shri Chandra Mohan Gargassessment Year: 2017-18 Smt. Mamta Gupta Ito Osd-1 Faridabad 100, Sector-19, Faridabad, Haryana 121002 Vs. Pan Agypg3143N (Appellant) (Respondent) For Assessee : Shri Suresh Kumar Gupta, Ca For Revenue : Shri Om Prakash, Sr Dr

For Appellant: Shri Suresh Kumar Gupta, CAFor Respondent: Shri Om Prakash, Sr DR

Section 115BSection 68

…ion is called for in the hands of assessee therefore remaining addition of Rs. 7 lakh as upheld by the Ld. CIT(A) may kindly be deleted. He also relied on the judgment of Hon’ble jurisdictional High Court of Delhi in the case of CIT vs Shri Kulwant Rai (2007) 291 ITR 36 (Del). 8. The Ld. Senior Departmental Representative strongly supported the orders of authorities below and submitted that the assessee could not explained the source of cash deposited to her bank account therefore the addition may kindly be confirmed. 9. On careful consideration of rival submissions, perusal of copy of computation of income, ca…