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.

525

judgments rely on this decision, according to BharatTax’s citation analysis of 372,576 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
Read the full judgment

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

Sri Udit Kumar Dugar, Kolkata vs. ITO, Ward - 36(4), Kolkata

In the result, the appeal of assessee is allowed

ITA 799/KOL/2018[2012-13]Status: DisposedITAT Kolkata03 May 2019AY 2012-13

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 143(2)Section 147Section 148

…Udit Kumar Dugar, AY 2012-13 probabilities. And while adjudicating the LTCG claim of assessee one should test it on the test of human probability and cited decisions of Hon’ble Apex Court, High Courts and Tribunal in following cases: i) CIT Vs. P. Mohankala 291 ITR 278 (SC), ii) CIT Vs. Durga Prasad More (1971) 82 ITR 540 (SC), iii) Sumati Dayal Vs. CIT (1995) 214 ITR 801 (SC), iv) Das & sons Vs. CIT (2003) 264 ITR 435 (Delhi), v) Smt. Phoolwati Devi 314 ITR (AT) 1 (Del.), vi) CIT Vs. N R. Portfolio Pvt. Ltd. dated 22.11.2013(Del.), vii) Chuhar Mal Vs. CIT (1988) 172 ITR 250, viii) M/s. Mont Blane Properties &…

Shri Shankar Lal Gokulka, Sikar vs. Income Tax Officer, Ward, Neem Ka Thana

In the result, appeal of the assessee is partly allowed

ITA 894/JPR/2018[2013-14]Status: DisposedITAT Jaipur30 Apr 2019AY 2013-14
For Appellant: Shri Shravan Kr. Gupta (Adv.)For Respondent: Ms. Anuradha (JCIT)
Section 143(3)Section 234Section 68

…as discharged its onus to prove the identity, creditworthiness and genuineness of the transactions. In support of his contention, he has relied upon the various decisions including the decision of the Hon’ble Supreme Court in the case of CIT vs. P. Mohanakala 291 ITR 278 (SC) and the decision of the Hon’ble Punjab & Haryana High Court in the case of CIT Vs. Varinder Rawlley 366 ITR 232 (P&H). The ld AR has thus submitted that the addition made by the A.O. may be deleted. 7 ITA 894/JP/2018_ Shankar Lal Gokulka Vs ITO 9. On the other hand, the ld DR has submitted that the A.O. has examined the loan creditor and fo…

DCIT CC 3(4) Cen RG 3, Mumbai vs. Mars Realtors P. Ltd, Mumbai

Appeals of the Revenue are dismissed

ITA 7180/MUM/2016[2013-14]Status: DisposedITAT Mumbai05 Apr 2019AY 2013-14

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…the income should get assessed in the year in which it is generated/earned. He further held that section 68 is not applicable since source of such money is evidenced in the impounded papers. He relied on the decisions in the case of [CIT .P Mohanakala (2007) 291 ITR 278 (SC)I1Hindusthan Tea Trading Co. Ltd. v .CIT (2003) 263 ITR 289, 293 (Cal). [Sreelekha Banerjee v. CIT, (1963) 49 ITR (SC) 112, 120, 121, D. YasodammaGudur v. CIT, (1968) 70 ITR (AP): Anil Kumar Singh v. CIT, (1972) 84 ITR 307 (Cal); Abu Bucker Sait v CIT, (1970) 76 ITR 362 (Mad).In this background, the CIT(A) deleted the addition made by the Ass…

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dev Land and Housing P.Ltd, Mumbai

Appeals of the Revenue are dismissed

ITA 7179/MUM/2016[2013-14]Status: DisposedITAT Mumbai05 Apr 2019AY 2013-14

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…the income should get assessed in the year in which it is generated/earned. He further held that section 68 is not applicable since source of such money is evidenced in the impounded papers. He relied on the decisions in the case of [CIT .P Mohanakala (2007) 291 ITR 278 (SC)I1Hindusthan Tea Trading Co. Ltd. v .CIT (2003) 263 ITR 289, 293 (Cal). [Sreelekha Banerjee v. CIT, (1963) 49 ITR (SC) 112, 120, 121, D. YasodammaGudur v. CIT, (1968) 70 ITR (AP): Anil Kumar Singh v. CIT, (1972) 84 ITR 307 (Cal); Abu Bucker Sait v CIT, (1970) 76 ITR 362 (Mad).In this background, the CIT(A) deleted the addition made by the Ass…

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dev Land and Housing P.Ltd, Mumbai

Appeals of the Revenue are dismissed

ITA 7178/MUM/2016[2010-11]Status: DisposedITAT Mumbai05 Apr 2019AY 2010-11

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…the income should get assessed in the year in which it is generated/earned. He further held that section 68 is not applicable since source of such money is evidenced in the impounded papers. He relied on the decisions in the case of [CIT .P Mohanakala (2007) 291 ITR 278 (SC)I1Hindusthan Tea Trading Co. Ltd. v .CIT (2003) 263 ITR 289, 293 (Cal). [Sreelekha Banerjee v. CIT, (1963) 49 ITR (SC) 112, 120, 121, D. YasodammaGudur v. CIT, (1968) 70 ITR (AP): Anil Kumar Singh v. CIT, (1972) 84 ITR 307 (Cal); Abu Bucker Sait v CIT, (1970) 76 ITR 362 (Mad).In this background, the CIT(A) deleted the addition made by the Ass…

DCIT CC 3(4) Cen RG 3, Mumbai vs. Dev Land and Housing P.Ltd, Mumbai

Appeals of the Revenue are dismissed

ITA 7177/MUM/2016[2009-10]Status: DisposedITAT Mumbai05 Apr 2019AY 2009-10

Bench: Shri G.S. Pannu & Shri Amarjit Singh

For Appellant: Shri T. Kipgen, CIT-DRFor Respondent: Shri Vijay Mehta
Section 132(1)Section 132(4)Section 143(3)Section 68

…the income should get assessed in the year in which it is generated/earned. He further held that section 68 is not applicable since source of such money is evidenced in the impounded papers. He relied on the decisions in the case of [CIT .P Mohanakala (2007) 291 ITR 278 (SC)I1Hindusthan Tea Trading Co. Ltd. v .CIT (2003) 263 ITR 289, 293 (Cal). [Sreelekha Banerjee v. CIT, (1963) 49 ITR (SC) 112, 120, 121, D. YasodammaGudur v. CIT, (1968) 70 ITR (AP): Anil Kumar Singh v. CIT, (1972) 84 ITR 307 (Cal); Abu Bucker Sait v CIT, (1970) 76 ITR 362 (Mad).In this background, the CIT(A) deleted the addition made by the Ass…

Smt. Sushila Devi Kajaria, Kolkata vs. ACIT, Circle - 36, Kolkata

ITA 1255/KOL/2018[2014-15]Status: DisposedITAT Kolkata03 Apr 2019AY 2014-15

Bench: Shri S.S, Godara

Section 143(3)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “SMC” KOLKATA Before Shri S.S, Godara, Judicial Member ITA No.1254-1255/Kol/2018 Assessment Year:2014-15 Naveen Kumar Kajaria ACIT, Circle-35, बनाम / 32, Armenian Street, Aayakar Bhawan, V/s. Kolkata-700001 Poorva, 110, Shantipally, 7th Floor, [PAN No.AGDPK 0069 N] Kolkakta-107 Smt. Sushila Devi Kajaria, बनाम / 32, Armenian Street, ACIT, Circle-36, V/s. Kolkata-001 Aaykar Bhawa, Poorva 110, Shantipally, 7th [PAN No.AFYPK 7990 Q] Floor, Kolkata-107 .. अपीलाथ" /Appellant ""यथ" /Respondent Shri Sunin Surana, Advocate & आवेदक क" ओर से/By Assessee Shri S.M. Surana, A…

Navin Kumar Kajaria, Kolkata vs. ACIT, Circle - 35, Kolkata

ITA 1254/KOL/2018[2014-15]Status: DisposedITAT Kolkata03 Apr 2019AY 2014-15

Bench: Shri S.S, Godara

Section 143(3)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA BENCH “SMC” KOLKATA Before Shri S.S, Godara, Judicial Member ITA No.1254-1255/Kol/2018 Assessment Year:2014-15 Naveen Kumar Kajaria ACIT, Circle-35, बनाम / 32, Armenian Street, Aayakar Bhawan, V/s. Kolkata-700001 Poorva, 110, Shantipally, 7th Floor, [PAN No.AGDPK 0069 N] Kolkakta-107 Smt. Sushila Devi Kajaria, बनाम / 32, Armenian Street, ACIT, Circle-36, V/s. Kolkata-001 Aaykar Bhawa, Poorva 110, Shantipally, 7th [PAN No.AFYPK 7990 Q] Floor, Kolkata-107 .. अपीलाथ" /Appellant ""यथ" /Respondent Shri Sunin Surana, Advocate & आवेदक क" ओर से/By Assessee Shri S.M. Surana, A…

Kemit Chemicals Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-2(1)(2), Ahmedabad

In the result, the appeal is allowed for statistical purposes in the terms indicated above

ITA 2593/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad26 Mar 2019AY 2014-15

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 2593/Ahd/2017 "नधा"रण वष"/Assessment Year: 2014-15 Kemit Chemicals P.Ltd. Ito, Ward-2(1)(2) 78/12, Gidc, Vatva, Phase-I Vs Ahmedabad. Vatva Ahmedabad 382 445. Pan : Aaack 5879 N अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.N. Divetia, Ar Revenue By : Shri T.C.Meena, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 25/03/2019 घोषणा क" तार"ख /Date Of Pronouncement : 26/03/2019

For Appellant: Shri S.N. Divetia, ARFor Respondent: Shri T.C.Meena, Sr.DR
Section 143(2)Section 195

…ach of agents were different. Further, the appellant's contention that the payments to them have been made through banking channels cannot be said to conclusive evidence in view of the judgment of Hon'ble Apex Court in the case of CIT Vs. P. Mohanakala (2007) 291 ITR 278 (SC). Thus, the identity of the agents have not been established and the appellant has also not been able to prove that any services have actually been rendered by these agents. 3.8. Foreign commission was paid to these two parties in the A. Y. 2012- 13 & CIT(A)-2, Ahmedabad has confirmed the disallowances. In view of the aforesaid discussion th…

Dilavarhusain R. Farasta, Ahmedabad vs. The Income Tax Officer, Ward-2(4), Bhavnagar

In the result, appeal of the assessee is dismissed

ITA 140/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad26 Mar 2019AY 2013-14

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. No.140/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2013-14)

For Appellant: Shri B.R. Popat, ARFor Respondent: Shri Rajesh Meena, Sr.DR

…आयकर अपील"य अ"धकरण, अहमदाबाद "यायपीठ ‘एस. एम. सी’, अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ SMC” BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, JUDICIAL MEMBER And SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No.140/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2013-14) Dilavarihusai R.Farasta The Income Tax बनाम/ Totaniya Kuvo Officer Vs. Dena Bank pase no khancho Ward-2(4) Mahuva Bhavnagar Dist.Bhavnagar-364 290 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AACPF 2973 R .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से / Appellant by : Shri B.R. Popat, AR ""यथ" क" ओर से/Respondent b…

Principal Commissioner of Income Tax(Central) 1 vs. Nra Iron and Steel Pvt. Ltd. Through Director

C.A. No.-002463-002463 - 2019Supreme Court05 Mar 2019

Bench: HON'BLE THE CHIEF JUSTICE

Section 148Section 68

…explanation” means the assessee offers no proper, reasonable and acceptable explanation as regards the sums found credited in the books maintained by the assessee. 8 [1995] 214 ITR 801 (SC) 9 291 ITR 278 20 The burden is on the assessee to take the plea that, even if the explanation is not acceptable, the material and attending circumstances available on record do not justify the sum found credited in the books being treated as a receipt of income nature.” (emphasis supplied) iii. The Delhi H…

The DCIT, Circle-4, Ahmedabad vs. Gujarat Infotech Limited, Ahmedabad

In the result, the appeal is allowed for statistical purposes in the terms indicated above

ITA 1371/AHD/2015[2011-12]Status: DisposedITAT Ahmedabad28 Feb 2019AY 2011-12
Section 143(3)Section 68

…ITA No. 1371/Ahd/2015 DCIT Vs. Gujarat Infotech Ltd Assessment Year : 2011-12 Page 1 of 8 IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH, AHMEDABAD [Coram: Pramod Kumar VP and Mahavir Prasad JM] Assessment Year: 2011-12 The Deputy Commissioner of Income-tax .......…………...........Appellant Circle 2(1)(1), Ahmedabad Vs. Gujarat Infotech Limited ............................Respondent A-2, 2nd Floor, Jay Tower, Ankur Compex, Nr. Ankur Bus Stop, Navrangpura, Ahmedabad-380006 [PAN : AABCG 6123 E] Appearances by: Saurabh Singh, for the Appellant S N Divatia, for the Respondent Date of concluding the hearing :…

The Dy. Commissioner of Income Tax, Central Circle-3, Surat vs. M/S. Happy Home Corporation, Surat

ITA 715/AHD/2017[2013-14]Status: DisposedITAT Surat15 Jan 2019AY 2013-14

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Rasesh Shah, CAFor Respondent: Smt.Smita Nair, Sr.DR
Section 131Section 133(6)Section 143(2)Section 68Section 80I

…(SC). There is popular doctrine of common law which says Incumbit Probatio qui digit non qui negat i.e. burden lies upon one who alleges and not upon who denies the existence of the fact. However, in subsequent decision in the case of CIT Vs. Mohnkala (2007) 291 ITR 278 (SC) Hon'ble Court has held that it is true that the opinion of the AO for not accepting the explanation offered by the assessee is not satisfactory is required to be based on proper appreciation of material and ITA No.1991/Ahd/2016 and 715/Ahd/2017 18 attending circumstances available on record. The opinion of the AO is required to be formed obj…

The Dy. Commissioner of Income Tax, Central Circle-3, Surat vs. M/S. Happy Home Corporation, Surat

ITA 1991/AHD/2016[2012-13]Status: DisposedITAT Surat15 Jan 2019AY 2012-13

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

For Appellant: Shri Rasesh Shah, CAFor Respondent: Smt.Smita Nair, Sr.DR
Section 131Section 133(6)Section 143(2)Section 68Section 80I

…(SC). There is popular doctrine of common law which says Incumbit Probatio qui digit non qui negat i.e. burden lies upon one who alleges and not upon who denies the existence of the fact. However, in subsequent decision in the case of CIT Vs. Mohnkala (2007) 291 ITR 278 (SC) Hon'ble Court has held that it is true that the opinion of the AO for not accepting the explanation offered by the assessee is not satisfactory is required to be based on proper appreciation of material and ITA No.1991/Ahd/2016 and 715/Ahd/2017 18 attending circumstances available on record. The opinion of the AO is required to be formed obj…

Shri Lalit Kumar Paryani, Ajmer vs. Assistant Commissioner of Income Tax, Circle-2, Ajmer

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

ITA 1107/JPR/2018[2014-15]Status: DisposedITAT Jaipur11 Jan 2019AY 2014-15
For Appellant: Shri Sunil Porwal (CA)For Respondent: Shri P.P. Meena (JCIT)
Section 131Section 68

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCH “A”, JAIPUR Jh fot; iky jkWo] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI VIJAY PAL RAO, JM AND SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 1107/JP/2018 fu/kZkj.k o"kZ@Assessment Year : 2014-15. cuke Shri Lalit Kumar Paryani, The ACIT Vs. Prop. M/s. Suresh & Company Circle-2, 21, Anasagar Link Road, Ajmer. Ajmer. LFkk;h ys[kk la-@thvkbZvkj la-@PAN No. AAWPP 1893 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by…

Zuberi Engineering Company, Jaipur vs. Deputy Commissioner of Income Tax, Circle-2, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 979/JPR/2018[2014-15]Status: DisposedITAT Jaipur18 Dec 2018AY 2014-15
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…inous with that of the Income-tax Officer. He can do what the Income-tax Officer can do and also direct him to do what he has failed to do." ITA 977 to 979/JP/2018 & 1122/JP/2018_ 21 Zuberi Engineering Vs DCIT. 41. As we can see, CIT v. P. Mohanakala [2007] 291 ITR 278/161 Taxman 169 (SC) deals with the powers of High Court in interfering with the findings of fact— and concurrent findings, at that—by re-appreciating the evidence. The Supreme Court has held in the negative. The Supreme Court in Jute Corpn. of India Ltd. v. CIT [1991] 187 ITR 688/[1990] 53 Taxman 85 has stated that the declaration of law is clear…

Zuberi Engineering Company, Jaipur vs. Deputy Commissioner of Income Tax, Circle-2, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 978/JPR/2018[2013-14]Status: DisposedITAT Jaipur18 Dec 2018AY 2013-14
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…inous with that of the Income-tax Officer. He can do what the Income-tax Officer can do and also direct him to do what he has failed to do." ITA 977 to 979/JP/2018 & 1122/JP/2018_ 21 Zuberi Engineering Vs DCIT. 41. As we can see, CIT v. P. Mohanakala [2007] 291 ITR 278/161 Taxman 169 (SC) deals with the powers of High Court in interfering with the findings of fact— and concurrent findings, at that—by re-appreciating the evidence. The Supreme Court has held in the negative. The Supreme Court in Jute Corpn. of India Ltd. v. CIT [1991] 187 ITR 688/[1990] 53 Taxman 85 has stated that the declaration of law is clear…

Zuberi Engineering Company, Jaipur vs. DCIT, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 977/JPR/2018[2012-13]Status: DisposedITAT Jaipur18 Dec 2018AY 2012-13
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…inous with that of the Income-tax Officer. He can do what the Income-tax Officer can do and also direct him to do what he has failed to do." ITA 977 to 979/JP/2018 & 1122/JP/2018_ 21 Zuberi Engineering Vs DCIT. 41. As we can see, CIT v. P. Mohanakala [2007] 291 ITR 278/161 Taxman 169 (SC) deals with the powers of High Court in interfering with the findings of fact— and concurrent findings, at that—by re-appreciating the evidence. The Supreme Court has held in the negative. The Supreme Court in Jute Corpn. of India Ltd. v. CIT [1991] 187 ITR 688/[1990] 53 Taxman 85 has stated that the declaration of law is clear…

Assistant Commissioner of Income Tax, Circle-2, Jaipur vs. Zuberi Engineering Company, Jaipur

In the result, all the three appeals of the assessee are partly allowed and that of revenue’s cross appeal is dismissed

ITA 1122/JPR/2018[2012-13]Status: DisposedITAT Jaipur18 Dec 2018AY 2012-13
For Appellant: Shri Kapil Goel (Adv)For Respondent: Shri Varinder Mehta (CIT-DR)
Section 143(3)Section 145(3)Section 251Section 40

…inous with that of the Income-tax Officer. He can do what the Income-tax Officer can do and also direct him to do what he has failed to do." ITA 977 to 979/JP/2018 & 1122/JP/2018_ 21 Zuberi Engineering Vs DCIT. 41. As we can see, CIT v. P. Mohanakala [2007] 291 ITR 278/161 Taxman 169 (SC) deals with the powers of High Court in interfering with the findings of fact— and concurrent findings, at that—by re-appreciating the evidence. The Supreme Court has held in the negative. The Supreme Court in Jute Corpn. of India Ltd. v. CIT [1991] 187 ITR 688/[1990] 53 Taxman 85 has stated that the declaration of law is clear…

Rajiv Chandran, New Delhi vs. ITO, Ward-32(5), New Delhi

In the result, the appeal of assessee is partly allowed

ITA 4713/DEL/2018[2010-11]Status: DisposedITAT Delhi12 Dec 2018AY 2010-11

Bench: Shri Bhavnesh Sainiassessment Year: 2010-11 Rajiv Chandran Vs Ito B-45, Gulmohar Park, Ward 32(5) New Delhi. New Delhi. Pan No. Akdpc3523B Appellant Respondent

Section 147

…he unexplained amount of the assessee which assessee tried to explain through the alleged gifts. I rely upon decision of the Delhi High Court in the case of CIT vs. Anil Kumar 292 ITR 552, decision of Hon’ble Supreme Court in the case of CIT vs. P. Mohan Kala 291 ITR 278 and decision of Hon’ble Punjab & Haryana High Court in the case of Yashpal Goel vs. CIT 6 AY 2010-11 Rajiv Chandran 310 ITR 75. Accordingly, no interference is called for in the matter. I, confirm the addition of Rs. 5 lakhs. 8. No other source of balance amounts have been explained and is not supported by any evidence. Ld. Counsel for assessee…