CIT v. M.Ganapathi Mudaliar

53 ITR 623Supreme Court of India1964#986 most cited

What is CIT v. M.Ganapathi Mudaliar authority for?

Where an assessee fails to satisfactorily explain the source and nature of a credit entry in their books or unexplained money, the amount can be treated as income, and the Revenue is not required to locate its exact source.

110

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. M.Ganapathi Mudaliar · M Ganapathi Mudaliar · Section 68 · Section 69A · Section 115BBE · onus of proof · unexplained cash credit · source and nature of credit · department not required to locate source · deemed income · satisfactory explanation

Sections most often in play

Section 68Section 115BBESection 143(3)Section 153ASection 69ASection 142(1)Section 143(2)Section 144

Issues it is cited on

section 106section 155bbesection 66section 2(9)section 2(12a)surrender of incomepeak credit theorycreditworthiness of the creditorincome tax settlement commissionsection 155onus of proofsurvey under section 133a

Judgments citing CIT v. M.Ganapathi Mudaliar

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. SHRI SHAILENDRA KUMAR GUPTA,

The appeals are dismissed

ITA/44/2025HC Rajasthan24 Mar 2026

Bench: SANJEEV PRAKASH SHARMA,SHUBHA MEHTA

Section 68

…e was derived and why it should be treated as concealed income. The assessee must prove satisfactorily the source and nature of cash received during the accounting year. Similarly the observations were made in CIT vs. M. Ganapathi Mudaliar [1964] 53 ITR 623 (SC), inter alia, holding that it was not necessary for the Revenue to locate the exact source. This principle was reiterated in CIT vs. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 (SC), wherein the contention that the Assessing Officer should indicate the source of income before it was taxable, was described as an incorrect le…

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. SHRI PAWAN GUPTA,

The appeals are dismissed

ITA/45/2025HC Rajasthan24 Mar 2026

Bench: SANJEEV PRAKASH SHARMA,SHUBHA MEHTA

Section 68

…e was derived and why it should be treated as concealed income. The assessee must prove satisfactorily the source and nature of cash received during the accounting year. Similarly the observations were made in CIT vs. M. Ganapathi Mudaliar [1964] 53 ITR 623 (SC), inter alia, holding that it was not necessary for the Revenue to locate the exact source. This principle was reiterated in CIT vs. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 (SC), wherein the contention that the Assessing Officer should indicate the source of income before it was taxable, was described as an incorrect le…

THE PRINCIPAL COMMISSIONER OF INCOME TAX, vs. SHRI RAJ RAJESHWARI GUPTA,

The appeals are dismissed

ITA/46/2025HC Rajasthan24 Mar 2026

Bench: SANJEEV PRAKASH SHARMA,SHUBHA MEHTA

Section 68

…e was derived and why it should be treated as concealed income. The assessee must prove satisfactorily the source and nature of cash received during the accounting year. Similarly the observations were made in CIT vs. M. Ganapathi Mudaliar [1964] 53 ITR 623 (SC), inter alia, holding that it was not necessary for the Revenue to locate the exact source. This principle was reiterated in CIT vs. Devi Prasad Vishwanath Prasad [1969] 72 ITR 194 (SC), wherein the contention that the Assessing Officer should indicate the source of income before it was taxable, was described as an incorrect le…

PRODIGY INFOMATICS PRIVATE LIMITED ,MUMBAI vs. ITO, 15(2)(4), MUMBAI

Accordingly, these grounds are dismissed

ITA 2124/MUM/2025[2012-13]Status: DisposedITAT Mumbai10 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Jagadishprodigy Infomatics Private Vs. Ito, 15(2)(4), Mumbai Limited Director Ito, 15(2)(4), Mumbai Plot No. D- 388, Midc, Ttc Aayakar Bhavan Industrial Area, Kukshet Mumbai- 400020 Village, Navi Mumbai - 400705 Pan/Gir No. Aadcp3211A (Applicant) (Respondent) Assessee By None Revenue By Shri Virabhadra Mahajan, (Sr. Dr) Date Of Hearing 04.03.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 18.02.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2012-13. The Following Grounds Are Reproduced Below: “1. On The Facts & In The Circumstances Of The Case & In Law, The Learned C.I.T. (A) Erred In Dismissing The Appeal.

Section 250Section 68

…year. the same may be charged to income-tax as income if the explanation of the assesse is not found to be satisfactory by the Assessing Officer. Reliance is also placed 6 on the decisions of the Hon'ble Supreme Court in the case of CIT vs. Ganapati Mudiliar 53 ITR 623. 5.8 In view of the above and also in light of various judicial pronouncements viz., Jalan Timbers vs. CIT, 223 ITR 11, CIT vs. Precision Finance Pvt.Ltd., 208 ITR 465 (CaL), Nizam Wool Agency vs. CIT, 193 ITR 318 (AIL), CIT vs. Korley Trading Co. Ltd., 23 ITR 820, M.S.Unneri Kutty vs. CIT 198 ITR 147 and R.B. Mittal vs. CIT 246 ITR 283, it is cle…

HOLLIS VITRIFIED PRIVATE LIMITED,MORBI, GUJARAT, INDIA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT, GUJARAT, INDIA

In the result, appeal filed by the assessee, is dismissed

ITA 363/RJT/2024[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 363/Rjt/2024 (Assessment Year: 2018-19) (Hybrid Hearing) Hollis Vitrified Pvt. Ltd. Vs. The Pr. Commissioner Of Income Revenue Survey No. 756/P1/P1/P1, Opp. Tax-1, Rajkot Antique Granito, Ghuntu,-Lakhdhirpur Road, Morbi (Gujarat)-363642 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacch5628Q (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Fenil H. Mehta, Ld. ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 263Section 68

…The assessee must prove satisfactorily the source and nature of cash received during the accounting year. Similarly, observations were made in Page 11 of 37 I.T.A No. 363/Rjt/2024 A.Y. 2018-19 Hollis Vitrified Pvt. Ltd. CIT v. M. Ganapathi Mudaliar [1964] 53 ITR 623 (SC), inter alia holding that it was not necessary for the Revenue to locate the exact source. This principle was reiterated in CIT v. Devi Prasad Vishwanath [1969] 72 ITR 194 (SC), wherein the contention that the Assessing Officer should indicate the source of income before it was taxable, was described as an incorrect legal position. Thus, when…

KISHOR RAMESHBHAI MEHTA,SURAT vs. ITO, WARD-1(5), BHARUCH

In the result, appeal of the assessee is allowed for statistical purpose

ITA 60/SRT/2025[2013-14]Status: DisposedITAT Surat10 Nov 2025AY 2013-14

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.60/Srt/2025 Assessment Year: 2013-14 (Hybrid Hearing) Kishor Rameshbhai Mehta Vs. Ito, Prop. Of Aditya Infrastructure, Ward - 1(5), 139, Maher Nagar, Opp. Baps Bharuch Hospital, Adajan Gam Circle, Surat - 395 009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adepm 4458 R (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 10/11/2025

Section 194ASection 194CSection 2(24)Section 250Section 253(3)Section 36(1)(iii)Section 40Section 68Section 69A

…idences/explanation had furnished. The AO relied upon various decision, viz. (i) Sumati Dayal vs. CIT, 214 ITR 801 (SC), (ii) Kale Khan Mohammad Hanif vs. CIT, 50 ITR 1 (SC), (iii) Roshan Di Hatti vs. CIT, 107 ITR 938 (SC), (iv) CIT vs. M. Ganapathi Mudaliar, 53 ITR 623 (SC), (v) A. Govindarajulu Mudaliar vs. CIT, 34 ITR 807 (SC), (vi) Shankar Industries vs. CIT, ITA No.60/SRT/2025/AY 2013-14 Kishor Rameshbhai Mehta 114 ITR 689, (vii) Shreelekha Banerjee vs. CIT, 49 ITR 112, (viii) CIT vs. Devi Prasad Vishwanath Prasad, 72 ITR 194 (SC), (ix) Bomin P. Ltd. vs. CIT, 160 ITR 477 (Guj.), (x) ITO vs. Diza Holdings…

RUPESH TAMBI,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, JAIPUR

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

ITA 1470/JPR/2024[2015-16]Status: DisposedITAT Jaipur29 Oct 2025AY 2015-16
For Appellant: Shri S. R. Sharma, CA &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 1Section 132Section 133ASection 271Section 271A

…charged satisfactorily, it is open to the Revenue to hold\nthat it is income of the assessee and no further burden lies on the Revenue to\nshow that income is from any other particular source. [As per principle laid down\nin CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar\nv. CIT [1958] 34 ITR 807 (SC)].\n(iii) Unexplained cash / unexplained investment cannot be presumed to be\nbusiness income. If the assesse claims so, the assesse is required to prove the\nsame. [Hon'ble Supreme Court in the case of Commissioner of Income-tax v.\nDevi Prasad Vishwanath [1969] 72 ITR 194 (SC)[01-08-19…

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

…Officer is Shri Ambika Garments vs. ACIT entitled to treat it as taxable income: see A. Govindarajulu Mudaliar v. Commissioner of Income-tax [1958] 34 ITR 807 (SC)". As per judgements of Hon'ble Supreme Court in the case of CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC), where the assessee has failed to prove satisfactorily the source and nature of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source. (10) INCOMES U/S 68, 69 ETC. ARE SEPARATE…

SANJAY KUMAR KARNANI,JAIPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

…Officer is Shri Ambika Garments vs. ACIT entitled to treat it as taxable income: see A. Govindarajulu Mudaliar v. Commissioner of Income-tax [1958] 34 ITR 807 (SC)". As per judgements of Hon'ble Supreme Court in the case of CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC), where the assessee has failed to prove satisfactorily the source and nature of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source. (10) INCOMES U/S 68, 69 ETC. ARE SEPARATE…

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTRAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

…Officer is Shri Ambika Garments vs. ACIT entitled to treat it as taxable income: see A. Govindarajulu Mudaliar v. Commissioner of Income-tax [1958] 34 ITR 807 (SC)". As per judgements of Hon'ble Supreme Court in the case of CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC), where the assessee has failed to prove satisfactorily the source and nature of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source. (10) INCOMES U/S 68, 69 ETC. ARE SEPARATE…

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JODHPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

…Officer is Shri Ambika Garments vs. ACIT entitled to treat it as taxable income: see A. Govindarajulu Mudaliar v. Commissioner of Income-tax [1958] 34 ITR 807 (SC)". As per judgements of Hon'ble Supreme Court in the case of CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC), where the assessee has failed to prove satisfactorily the source and nature of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source. (10) INCOMES U/S 68, 69 ETC. ARE SEPARATE…

SHRI AMBICA GARMENTS, JODHPUR,JODHPUR vs. ACIT, CENTAL CIRCLE-3, JAIPUR, JAIPUR

In the result, all appeals of the assessee are disposed off in terms of

ITA 57/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

…Officer is Shri Ambika Garments vs. ACIT entitled to treat it as taxable income: see A. Govindarajulu Mudaliar v. Commissioner of Income-tax [1958] 34 ITR 807 (SC)". As per judgements of Hon'ble Supreme Court in the case of CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC), where the assessee has failed to prove satisfactorily the source and nature of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source. (10) INCOMES U/S 68, 69 ETC. ARE SEPARATE…

PRADEEP JAIN,JAIPUR vs. DCIT-CENTRAL CIRCLE-2, JAIPUR

25. As a result, this appeal deserves to be allowed

ITA 937/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 Oct 2025AY 2017-18

Bench: Learned Cit(A), While Challenging The Assessment Order Dated 27.12.2019, Passed By The Assessing Officer, As Regards Assessment Year 2017-18. That Appeal Came To Be Dismissed.

For Appellant: Shri Avinash Khandelwal, C.AFor Respondent: Smt. Alka Gautam, CIT
Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 68

…ged the onus with respect to proving the identity, genuineness and creditworthiness of the credits received.” 15. In support of the above observations, Learned CIT(A) relied on the following decisions:- 8 Pradeep Jain, Jaipur  M. Ganapathi Mudaliar, (1964) 53 ITR 623 (SC).  A. Govindarajulu Mudaliar v. CIT, (1958) 34 ITR 807 (SC).  Roshan di Hatti v Commissioner of Income-tax, (1977) 107 ITR 938 (SC)  Kale Khan Mohammad Hanif v. CIT, (1963) 50 ITR 1 (SC). 16. Hence, the appellant is before this Appellate Tribunal. Contentions 17. Ld. AR for the appellant has submitted that from the seized material it can…

PEEYUSH AGARWAL,JAIPUR, RAJASTHAN vs. ITO, WARD 1(5), JAIPUR, JAIPUR, RAJASTHAN

In the result Ground and 1 and 2 raised by the assessee are allowed

ITA 488/JPR/2025[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vijay Goyal, C.A. &For Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 143(2)Section 143(3)Section 145(3)Section 250Section 68Section 69A

…(Raj.) (ii) CIT vs. P.Mohanakala (2007) 291 ITR 278 (SC) (iii) Nemi Chand Kothari vs. CIT (2003) 264 ITR 254 (Gauhati) (iv) CIT vs. Precision Finance (P) Ltd. (1994) 208 ITR 465 (Calcutta) 11 Peeyush Agarwal, Jaipur. (v) CIT vs. M.Ganapathi Mudaliar (1964) 53 ITR 623 (SC) (vi) A.Govindarajulu Mudaliar vs. CIT (1958) 34 ITR 807 (SC) (vii) Sreelekha Banerjee vs. CIT (1963) 49 ITR 112 (SC) (viii) Renu T. Tharani vs. DCIT ITA no. 2333/Mum/2018-ITAT- Mumbai. (ix) Durai Murugan Kathir Anand vs. Addl CIT (2022) 443 ITR 423 (Madras) (x) Vivek N. Jajodia vs. ITO (2010) 123 ITD 136 (Mumbai) (xi) Konathala Nooku Naidu…

RAGHAV KUMAR DHOOT,JAIPUR vs. DCIT CENTRAL CIRCLE 1, JAIPUR

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

ITA 491/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19
For Appellant: Shri C.M. Agarwal, C.AFor Respondent: Shri Rajesh Ojha, CIT- DR
Section 143(2)Section 143(3)Section 153ASection 292BSection 68

…ailed to prove satisfactorily the source\nand nature of a credit entry in his books, and it is held that the relevant\namount is the income of the assesse, it is not necessary for the\ndepartment to locate its exact source (CIT v. M.Ganapathi Mudaliar\n[1964] 53 ITR 623 (SC)/A Govindarajulu Mudaliar v. CIT [1958] 34 ITR\n807 (SC)). Further source can also not be presumed (Commissioner of\nIncome-tax v. Devi Prasad Vishwanath [1969] 72 ITR 194 (SC))\nWhere the assessee has failed to prove satisfactorily the source and\nnature of a credit entry in his books, and it is held that the relevant\namount is the income of…

RAJENDRA AGARWAL,JAIPUR vs. DCIT, CENTRAL CIRCLE-1, JAIPUR

Appeal is hereby dismissed

ITA 560/JPR/2024[2017-18]Status: DisposedITAT Jaipur30 Jul 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Manish Dharnidharka, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 68

…has failed to prove satisfactorily the source and nature of a credit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source CIT v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC), A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC). The explanation of the assessee is to be seen in totality and as a whole and the same can either be found satisfactory or not satisfactory as a whole. The story or the explanation of the assessee cannot be modified by the Ld. AO or appellate authority. It is possible that a single mate…

MAHENDRA SINGH NARUKA,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result, the appeal of the assesseein ITA no

ITA 205/JPR/2025[2016-17]Status: DisposedITAT Jaipur04 Jun 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 204 & 205/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2015-16 & 2016-17 Shri Mahendra Singh Naruka B-536, J.D.A. Colony Malivya Nagar, Jaipur 302 017 अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABUPN 1656 J बनाम Vs. The ACIT Central Circle-3 Jaipur प्रत्यर्थी / Respondent निधर्धारिती की ओरसे / Assesseeby : Shri S.R. Sharma, Advocate राजस्व की ओरसे /Revenue by : Mrs. Anita Rinesh

For Appellant: Shri S.R. Sharma, AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR a
Section 115BSection 143(3)Section 153ASection 68

…edit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source (CIT SHRI MANHENDRA SINGH NARUKA VS DCIT, CENTRAL CIRCLE-3, JAIPUR v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC)). In the case of Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08-03-1977] it is held by the Hon'ble Supreme Court as under- "Now, the law is well settled that the onus of proving the source of a sum of money found to have been received by an assessee is on him. I…

MAHENDRA SINGH NARUKA,JAIPUR vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, JAIPUR

In the result, the appeal of the assesseein ITA no

ITA 204/JPR/2025[2015-16]Status: DisposedITAT Jaipur04 Jun 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 204 & 205/JPR/2025 निर्धारणवर्ष / AssessmentYears : 2015-16 & 2016-17 Shri Mahendra Singh Naruka B-536, J.D.A. Colony Malivya Nagar, Jaipur 302 017 अपीलार्थी / Appellant बनाम Vs. The ACIT Central Circle-3 Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ABUPN 1656 J निधर्धारिती की ओरसे / Assesseeby : Shri S.R. Sharma, Advocate राजस्व की ओरसे /Revenue by : Mrs. Anita Rinesh

For Appellant: Shri S.R. Sharma, AdvocateFor Respondent: Mrs. Anita Rinesh, JCIT -DR a
Section 115BSection 143(3)Section 153ASection 68

…edit entry in his books, and it is held that the relevant amount is the income of the assesse, it is not necessary for the department to locate its exact source (CIT SHRI MANHENDRA SINGH NARUKA VS DCIT, CENTRAL CIRCLE-3, JAIPUR v. M.Ganapathi Mudaliar [1964] 53 ITR 623 (SC)/A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR 807 (SC)). In the case of Roshan Di Hatti v. Commissioner of Income-tax [1977] 107 ITR 938 (SC)[08-03-1977] it is held by the Hon'ble Supreme Court as under- "Now, the law is well settled that the onus of proving the source of a sum of money found to have been received by an assessee is on him. I…

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, , JAIPUR

ITA 1465/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 May 2025AY 2017-18
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…failed to prove satisfactorily the source and nature of a credit entry in his\nbooks, and it is held that the relevant amount is the income of the assesse, it is not\nnecessary for the department to locate its exact source CIT v. M.Ganapathi\nMudaliar [1964] 53 ITR 623 (SC), A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR\n807 (SC).\n(iii) The explanation of the assesse is to be seen in totality and as a whole and the\nsame can either be found satisfactory or not satisfactory as a whole. The story or\nthe explanation of the assessee cannot be modified to allow relief. It is possible\nthat a single material fact o…

KAILASH CHAND MAHESHWARI,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX,CENTRALCIRCLE-2, JAIPUR

ITA 1464/JPR/2024[2016-17]Status: DisposedITAT Jaipur20 May 2025AY 2016-17
For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

…failed to prove satisfactorily the source and nature of a credit entry in his\nbooks, and it is held that the relevant amount is the income of the assesse, it is not\nnecessary for the department to locate its exact source CIT v. M.Ganapathi\nMudaliar [1964] 53 ITR 623 (SC), A. Govindarajulu Mudaliar v. CIT [1958] 34 ITR\n807 (SC).\n(iii) The explanation of the assesse is to be seen in totality and as a whole and the\nsame can either be found satisfactory or not satisfactory as a whole. The story or\nthe explanation of the assessee cannot be modified to allow relief. It is possible\nthat a single material fact o…

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