CIT v. P. Mohanakala

291 ITR 278Supreme Court of India2007#125 most cited

What is CIT v. P. Mohanakala authority for?

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

520

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2026.

Also referred to as

CIT v. P. Mohanakala · 291 ITR 278 · Section 68 · Section 69A · Section 69C · unexplained cash credit · undisclosed income · circumstantial evidence · burden of proof · assessee rebuttal · preponderance of probability · genuineness of transaction

Also reported as

161 Taxmann 169210 CTR 20

Sections most often in play

Section 68Section 143(3)Section 147Section 115BBESection 69CSection 133(6)Section 148Section 69A

Issues it is cited on

creditworthiness of the creditorsource of sourceaddition under section 68addition u/s 68genuineness of the transactionshare application moneyentry operatorunexplained cash creditprincipal commissioner of income-taxincome-tax officersection 131section 69c

Judgments citing CIT v. P. Mohanakala

ABHISHEKBHAI ASHOKBHAI PATEL,KADI vs. THE ITO, WARD 1, MEHSANA

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

ITA 1803/AHD/2025[2010-11]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Deepak, ARFor Respondent: Smt. Ananya Kulshresth, Sr. DR
Section 133(6)Section 144Section 147Section 69A

…he CIT(Appeals) further observed that no documentary trail linking withdrawals to deposits or evidence of share trading activity was produced. Accordingly, relying on the provisions of section 69A and judicial precedents including CIT vs. P. Mohanakala (2007) 291 ITR 278 (SC) and Kale Khan Mohammad Hanif vs. CIT (1963) 50 ITR 1 (SC), the CIT(Appeals) upheld the addition and dismissed Ground No. 1. In Ground No. 2, the assessee contended that since income from share transactions was below the taxable limit, return of income was not filed. The CIT(Appeals) held that this contention was irrelevant to the issue of un…

AMMATI VENKATACHALAPATHISETTY SATISH KUMAR,CHINTAMANI vs. INCOME TAX OFFICER, WARD-1, CHIKKABALLAPUR

ITA 2041/BANG/2025[2018-19]Status: DisposedITAT Bangalore24 Feb 2026AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 133(6)Section 133ASection 147Section 250Section 44A

…IN THE INCOME TAX APPELLATE TRIBUNAL 'SMC' BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.2039 - 2041/Bang/2025 Assessment Year: 2015-16, 2017-18 & 2018-19 Shri Ammati Venkatachalapathisetty Satishkumar, No.2, Kumar Traders, M.G Road, KRS Complex, Chintamani - 563 125. Vs. The Income Tax Officer, Ward - 1, Chikkaballapur. PAN – AHEPS 5992 C APPELLANT RESPONDENT Assessee by Smt. Sheettal, Advocate Revenue by Shri Ganesh R Ghale, Advocate – Standing Counsel for Revenue Date of hearing 03.02.2026 Date of Pronouncement 24.02.2026 ORDER PER WASEEM AHMED, ACC…

AMMATI VENKATACHALAPATHISETTY SATISH KUMAR,CHINTAMANI vs. INCOME TAX OFFICER, WARD-1,, CHIKKABALLAPUR

ITA 2040/BANG/2025[2017-18]Status: DisposedITAT Bangalore24 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheettal, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 133(6)Section 133ASection 147Section 250Section 44A

…IN THE INCOME TAX APPELLATE TRIBUNAL 'SMC' BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.2039 - 2041/Bang/2025 Assessment Year: 2015-16, 2017-18 & 2018-19 Shri Ammati Venkatachalapathisetty Satishkumar, No.2, Kumar Traders, M.G Road, KRS Complex, Chintamani - 563 125. Vs. The Income Tax Officer, Ward - 1, Chikkaballapur. PAN – AHEPS 5992 C APPELLANT RESPONDENT Assessee by : Smt. Sheettal, Advocate Revenue by : Shri Ganesh R Ghale, Advocate – Standing Counsel for Revenue Date of hearing Date of Pronouncement : 03.02.2026 : 24.02.2026 ORDER PER WASEEM AH…

AMMATI VENKATACHALAPATHISETTY SATISH KUMAR ,CHINTAMANI vs. INCOME TAX OFFICER, WARD-1, CHIKKABALLAPUR

ITA 2039/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Feb 2026AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: 03.02.2026
Section 133(6)Section 133ASection 147Section 250Section 44A

…ITA No.2039 - 2041/Bang/2025 Page 1 of 20 IN THE INCOME TAX APPELLATE TRIBUNAL 'SMC' BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No.2039 - 2041/Bang/2025 Assessment Year: 2015-16, 2017-18 & 2018-19 Vs. Shri Ammati Venkatachalapathisetty Satishkumar, No.2, Kumar Traders, M.G Road, KRS Complex, Chintamani - 563 125. PAN – AHEPS 5992 C APPELLANT Assessee by Revenue by Date of hearing Date of Pronouncement : Smt. Sheettal, Advocate : Shri Ganesh R Ghale, Advocate – Standing Counsel for Revenue : 03.02.2026 : 24.02.2026 ORDER PER WASEEM AHMED, ACCOUNTANT MEM…

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

…9 of 37 I.T.A No. 363/Rjt/2024 A.Y. 2018-19 Hollis Vitrified Pvt. Ltd. give explanation about nature & source on three basic ingredients, the explanation has to be proper, reasonable & acceptable. Hon'ble Supreme Court in the case of CIT VS. P. Mohanakala 291 ITR 278 (SC), while considering the scope of section 68, observed that the expression the assessee offers no explanation means where the assessee offer no proper, reasonable and acceptable explanation as regards the sums found credited in the books maintained by the assessee. While discussing the phrases proper, reasonable & acceptable, Hon'ble Apex Cour…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3(3), KOLKATA, KOLKATA vs. ADHUNIK INFRASTRUCTURES PRIVATE LIMITED , KOLKATA

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

ITA 1069/KOL/2024[2015-16]Status: DisposedITAT Kolkata09 Feb 2026AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 131Section 131(1)Section 143(3)Section 148Section 250Section 68Section 69A

…sonably reject it. On the other hand, if the explanation is unconvincing, the same can be rejected and an inference shows that the amount represents undisclosed income either from a disclosed or an undisclosed source CIT v. P. Mohanakala [2007] 161 Taxman 169/291 ITR 278/210 CTR 20 (SC). The explanation given by the assessee cannot be rejected arbitrarily or capriciously, without sufficient ground on suspicion or on imaginary or irrelevant grounds Lal Mohan Krishna Lal Paul v. CIT ITA No.: 1069/KOL/2024 Assessment Year: 2015-16 Adhunik Infrastructures Private Limited. [1944] 12 ITR 441 (Cal.) and Anil Kumar Singh…

V GAYATHRI,KRISHNAGIRI vs. ITO, WARD-1,, KRISHNAGIRI

The appeal of the assessee is partly allowed

ITA 1871/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Feb 2026AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri. S. Jecintha, AdvocateFor Respondent: Ms. Gouthami Manivasagam, J.C.I.T
Section 143(2)Section 143(3)Section 69

…आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी जॉज" जॉज" के, उपा"य" एवं "ी एस.आर.रघुनाथा, लेखा सद%य के सम" BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:1871/Chny/2025 'नधा"रण वष" / Assessment Year: 2017-18 V. Gayathri, Income Tax Officer, No.114, West Mada Street, vs. Ward -1, Krishnagiri – 635 001. Krishnagiri. [PAN:AHHPG-7395-L ] (अपीलाथ)/Appellant) (*+यथ)/Respondent) अपीलाथ) क, ओर से/Appellant by : Shri. S. Jecintha, Advocate *+यथ) क, ओर से/Respondent by : Ms. Gouthami Manivasagam, J.C.I.T…

OHM DEVELOPERS,SABARKANTHA vs. THE ACIT, CIRCLE, HIMATNAGAR

In the result, the appeal of the assessee is dismissed

ITA 1538/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalohm Developers The Acit, Circle Vs. C/O. Bhandari Marketing Income Tax Office 1, Manish Market Himatnagar – 395 001 Nr. Old State Bank Nava Bazar, Himatnagar – 383 001 (Sabarkantha Dist.) [Pan : Aacfo 2907 N] (Appellant) .. (Respondent) Assessee Represented By : Shri Tej Shah, Advocate Revenue Represented By : Shri Abhijit, Sr.Dr 27/11/2025 Date Of Hearing Date Of Pronouncement 29/01/2026

Section 143(3)Section 271ASection 68Section 69A

…universal proposition. Courts have consistently held that mere availability of withdrawals is not sufficient and the assessee must also establish that the withdrawn cash remained unutilised and was available for redeposit. In the case of CIT v. P. Mohanakala (291 ITR 278) (SC), the Hon’ble Supreme Court has held that the explanation of the assessee must be satisfactory and acceptable on the touchstone of human probabilities. 8.4. In the present case, the assessee has failed to demonstrate that the cash withdrawn over several months remained intact and unutilised and that there was any compelling business necessi…

SANOWAR ALI KHAN ,KOLKATA vs. ITO, WARD 25(1),, KOLKATA

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1503/KOL/2025[2022-2023]Status: DisposedITAT Kolkata28 Jan 2026AY 2022-2023

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 250Section 271ASection 282

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D’ BENCH, KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No.: 1503/KOL/2025 Assessment Year: 2022-23 Sanowar Ali Khan ITO, Ward-25(1), Kolkata Vs. (Appellant) (Respondent) PAN: DSQPK0325F Appearances: Assessee represented by : Rajesh Singh, AR. Department represented by : S.B. Chakraborthy, Sr. DR. Date of concluding the hearing : 26-November-2025 Date of pronouncing the order : 28-January-2026 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of the Commissioner of Income…

GEETA BABU SAWANT,MUMBAI vs. ITO 22(1)(1), MUMBAI

In the result, the appeal filed by the Revenue stands

ITA 138/MUM/2026[AY 2017-18]Status: FixedITAT Mumbai12 Jan 2026

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 131Section 133(6)Section 143(3)Section 147Section 250Section 292BSection 68

…1 IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER ITA No. 138/Mum/2025 A.Ys: 2013-14 ACIT, CC-7(3) Vs Swikrutee Finance Pvt Room No. 655, Floor 6th Ltd., Aayakar Bhavan, MK Road, Mumbai - 400020 Office No. II, 289 Emca House, SBS Road, Mumbai – 400 001. PAN – AAOCS2723H (Appellant) (Respondent) Assessee by Shri Vimal Punamiya Revenue by Ms. Kavitha kaushik, Sr. DR (Virutal appeared) Date of Hearing 18.11.2025 Date of Pronouncement 12.01.2026 ORDER PER SANDEEP GOSAIN, JM: This appeal has been filed by the assessee challeng…

JASTEJ GOROWARA,BHOPAL vs. COMMISSIONER OF INCOME-TAX (APPEALS), DELHI

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

ITA 277/IND/2025[2015-16]Status: DisposedITAT Indore23 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

…to establish the source of cash deposits made prior to advancing the loans, that their creditworthiness was not proved and that the genuineness of the transactions was doubtful. The Assessing Officer, placed reliance on the cases of CIT v. P. Mohankala (2007) 291 ITR 278 (SC), CIT v. Durga Prasad More (1971) 82 ITR 540 (SC) and Sumati Dayal v. CIT (1995) 214 ITR 801 (SC), held that the assessee had failed to discharge the onus of proving identity, creditworthiness and genuineness of the loan transactions. Accordingly, the unsecured loans of ₹90,00,000/- were treated as unexplained cash credits and added to the to…

JASTEJ GOROWARA,BHOPAL vs. CIT(A), DELHI

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

ITA 276/IND/2025[2011-12]Status: DisposedITAT Indore23 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

…to establish the source of cash deposits made prior to advancing the loans, that their creditworthiness was not proved and that the genuineness of the transactions was doubtful. The Assessing Officer, placed reliance on the cases of CIT v. P. Mohankala (2007) 291 ITR 278 (SC), CIT v. Durga Prasad More (1971) 82 ITR 540 (SC) and Sumati Dayal v. CIT (1995) 214 ITR 801 (SC), held that the assessee had failed to discharge the onus of proving identity, creditworthiness and genuineness of the loan transactions. Accordingly, the unsecured loans of ₹90,00,000/- were treated as unexplained cash credits and added to the to…

ACIT CENTRAL CIRCLE 1(4) MUMBAI, MUMBAI vs. KALYANEE FORTUNE CONSTRUCTIONS, MUMBAI

In the result, all the above appeals in ITA Nos

ITA 5779/MUM/2024[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…umstances and in law the Ld. CIT(A) overlooked the doctrine of preponderance of probability by dismissing the possibility that the assessee received a share of undisclosed cash income in a joint real estate venture, is laid out in CIT us. P. Mohanakala (2007) 291 ITR 278 (SC), where the Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight?” 5. “Whether on the facts and circumstances and in law the Ld. CIT(A) erred in deleting the addition of Rs.7,17,10,866/ made on account of “On Money” received, which is not disclosed in books of acco…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1(4), MUMBAI vs. KALYANEE FORTUNE CONSTRUCTIONS, MUMBAI

In the result, all the above appeals in ITA Nos

ITA 4448/MUM/2024[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18
Section 131Section 132(1)Section 133ASection 143(3)

…tances and in law the Ld. CIT(A) overlooked the\ndoctrine of preponderance of probability by dismissing the possibility that the\nassessee received a share of undisclosed cash income in a joint real estate venture, is\nlaid out in CIT us. P. Mohanakala (2007) 291 ITR 278 (SC), where the Supreme\nCourt emphasized that in the absence of concrete rebuttal by the assessee,\ncircumstantial evidence holds significant weight?”\n5. “Whether on the facts and circumstances and in law the Ld. CIT(A) erred in deleting\nthe addition of Rs.7,17,10,866/ made on account of “On Money” received, which is\nnot disclosed in books of…

ASSISTANT COMMISSIONER OF INCOME TAX , MUMBAI vs. KALYANEE FORTUNE CONSTRUCTIONS, MUMBAI

In the result, all the above appeals in ITA Nos

ITA 4445/MUM/2024[2018-19]Status: DisposedITAT Mumbai23 Dec 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…umstances and in law the Ld. CIT(A) overlooked the doctrine of preponderance of probability by dismissing the possibility that the assessee received a share of undisclosed cash income in a joint real estate venture, is laid out in CIT us. P. Mohanakala (2007) 291 ITR 278 (SC), where the Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight?” 5. “Whether on the facts and circumstances and in law the Ld. CIT(A) erred in deleting the addition of Rs.7,17,10,866/ made on account of “On Money” received, which is not disclosed in books of acco…

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 1 4 MUMBAI, MUMBAI vs. MS. KALYANEE FORTUNE CONSTRUCTIONS , MUMBAI

In the result, all the above appeals in ITA Nos

ITA 4444/MUM/2024[2020-21]Status: DisposedITAT Mumbai23 Dec 2025AY 2020-21
For Appellant: \nShri Neelkanth Khandelwal, ARFor Respondent: \nMs. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

…tances and in law the Ld. CIT(A) overlooked the\ndoctrine of preponderance of probability by dismissing the possibility that the\nassessee received a share of undisclosed cash income in a joint real estate venture, is\nlaid out in CIT us. P. Mohanakala (2007) 291 ITR 278 (SC), where the Supreme\nCourt emphasized that in the absence of concrete rebuttal by the assessee,\ncircumstantial evidence holds significant weight?\"\n5. “Whether on the facts and circumstances and in law the Ld. CIT(A) erred in deleting\nthe addition of Rs.7,17,10,866/ made on account of “On Money” received, which is\nnot disclosed in books o…

ASHOK HIRACHAND SHAH,PANVEL vs. ASSESSING OFFICER WARD 2, PANVEL

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

ITA 812/PUN/2025[2011-12]Status: DisposedITAT Pune17 Dec 2025AY 2011-12

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

For Appellant: Shri Ajinkya ShahFor Respondent: Shri Rajesh Gawali
Section 147Section 69A

…आयकर अपीलीय अधिकरण “ए” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, PUNE BEFORE SHRI R.K. PANDA, VICE PRESIDENT AND MS. ASTHA CHANDRA, JUDICIAL MEMBER आयकर अपील सं. / ITA No.812/PUN/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 PAN : ACDPS4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee by : Shri Ajinkya Shah Department by : Shri Rajesh Gawali Date of hearing : 09-12-2025 Date of 17-12-2025 Pronouncement : आदेश / ORDER PER ASTHA CHA…

MANOJ ANAND,GUWAHATI vs. ITO W-2(2) GHY, GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 273/GTY/2024[2018-19]Status: DisposedITAT Guwahati02 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Manoj Anand Ito W-2(2), Ghy Flat 4D, Garima Grand, Aaykar Bhawan, Christian Basti, Departmental Representative B. G.S. Road, Guwahati-781005, Vs. Baruah Road, Guwahati-781007, Assam Assam (Appellant) (Respondent) Pan No. Agbpa9883C

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Sanjay Jha, DR
Section 144BSection 147Section 148Section 68

…sonably reject it. On the other hand, if the explanation is unconvincing, the same can be rejected and an inference shows that the amount represents undisclosed income either from a disclosed or an undisclosed source CIT v. P. Mohanakala [2007] 161 Taxman 169/291 ITR 278/210 CTR 20 (SC). The explanation given by the assessee cannot be rejected arbitrarily or capriciously, without sufficient ground on suspicion or on imaginary or irrelevant grounds Lal Mohan Krishna Lal Paul v. CIT [1944] 12 ITR 441 (Cal.) and Anil Kumar Singh v. CIT [1972] 84 ITR 307 (Cal.). 5. Further to be noted that where the assessee furnishe…

LATE SHRI RAMANAND TAPARIA TH/LH CHANDADEVI TAPARIA ,INDORE vs. NATIONAL FACELESS ASSESSMENT CENTREQ, DELHI

ITA 262/IND/2025[2013-14]Status: DisposedITAT Indore21 Nov 2025AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 147Section 148Section 250Section 253Section 271(1)(c)

…oof lies on the assessee to prove the identity, creditworthiness, and genuineness of the transaction. A mere payment through banking channels does not establish genuiiness of the transaction, as per Supreme Court precedents [e.g., CIT vs. P. Mohanakala (2007) 291 ITR 278 (SC)]. Appeal for AY 2013-14 and AY 2014-15 are dismissed”. 2.15 That the assessee being aggrieved by the “impugned order" has preferred the instant second appeal before this Tribunal and has raised following grounds of appeal in the Form No.36 against the “impugned order” which are as under:- "1. The Ld. CIT(A) NFAC has erred in upholding the re…

LATE SHRI RAMANAND TAPARIA TH/LH CHANDA DEVI TAPARIA,INDORE vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

ITA 261/IND/2025[2014-15]Status: DisposedITAT Indore21 Nov 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 147Section 148Section 250Section 253Section 271(1)(c)

…f lies on the assessee to prove the identity, creditworthiness, and genuineness of the transaction. A mere payment through banking channels does not establish genuiineness of the transaction, as per Supreme Court precedents [e.g., CIT vs. P. Mohanakala (2007) 291 ITR 278 (SC)]. Appeal for AY 2013-14 and AY 2014-15 are dismissed”. 2.15 That the assessee being aggrieved by the “impugned order" has preferred the instant second appeal before this Tribunal and has raised following grounds of appeal in the Form No.36 against the “impugned order” which are as under:- "1. The Ld. CIT(A) NFAC has erred in upholding the re…

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