India Rice Mills v. CIT

218 ITR 508High Court1996#3231 most cited

What is India Rice Mills v. CIT authority for?

When partners make capital contributions to a firm, it is the partners' responsibility to explain the source of these funds. If they fail to do so, these contributions cannot be treated as the firm's income, even if recorded in the firm's books.

37

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2016 to 2026.

Also referred to as

India Rice Mills v. CIT · 218 ITR 508 · onus of proof · capital contribution · unexplained source · partnership firm · addition under section 68 · section 145(3) · section 271(1)(c) · section 68 · section 143(3)

Also reported as

85 Taxmann 227

Sections most often in play

Section 250Section 68Section 144Section 143(3)Section 145(3)Section 153ASection 153DSection 271(1)(c)

Issues it is cited on

section 155bbesection 2(9)section 256(1)section 66section 256section 116onus of proofsection 155survey under section 133asection 269ssaddition under section 68section 271d

Judgments citing India Rice Mills v. CIT

Dev Bullion, Mumbai vs. Deputy Commissioner of Income Tax Circle 23(1), Mumbai

ITA 3962/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Mr. Poojan Mehta, ARFor Respondent: Assessee by
Section 143(2)Section 143(3)Section 69C

…that any addition in the hands of partnership firm cannot made 4 Dev Bullion for unexplained capital brought in by the partner/firm. The ld. AR placed his reliance on the following judgments: 1. Narayandas Kedarnath 22 ITR 18 (Bom - HC) 2. India Rice Mills 85 Taxmann 227 (All-HC) 3. Shivam Developers 4. Arham Star 5. Mohammed Haji Adam & Co. 103 Taxmann.com 459 (Bom-HC) 5. Alternatively, Ld. AR, without prejudice to the aforesaid contentions, submitted that, even if the stock brought by the partner is considered to be unexplained on the part of assessee, which though was never queried to or enquired from the…

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, 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

…e case of CIT vs. Metachem Industries 245 ITR 160. Hence, following the aforesaid precedents, we do not see any infirmity in the well reasoned order of the Ld. CIT(A), same is thereby upheld. ” (c) We further rely upon the decision of India Rice Mills v. CIT 218 ITR 508, 511 (All. HC) wherein it was held that where the capital contributions are made by the partners, it is for the partners to explain the source of such capital contributions and if they fail to discharge such onus then such capital contributions, although entered in the books of accounts of the assessee-firm, cannot be regarded as income of the as…

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, 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

…e case of CIT vs. Metachem Industries 245 ITR 160. Hence, following the aforesaid precedents, we do not see any infirmity in the well reasoned order of the Ld. CIT(A), same is thereby upheld. ” (c) We further rely upon the decision of India Rice Mills v. CIT 218 ITR 508, 511 (All. HC) wherein it was held that where the capital contributions are made by the partners, it is for the partners to explain the source of such capital contributions and if they fail to discharge such onus then such capital contributions, although entered in the books of accounts of the assessee-firm, cannot be regarded as income of the as…

Shri Ambica Garments, Jodhpur vs. ACIT, Central Circle-3, 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

…e case of CIT vs. Metachem Industries 245 ITR 160. Hence, following the aforesaid precedents, we do not see any infirmity in the well reasoned order of the Ld. CIT(A), same is thereby upheld. ” (c) We further rely upon the decision of India Rice Mills v. CIT 218 ITR 508, 511 (All. HC) wherein it was held that where the capital contributions are made by the partners, it is for the partners to explain the source of such capital contributions and if they fail to discharge such onus then such capital contributions, although entered in the books of accounts of the assessee-firm, cannot be regarded as income of the as…

Shri Ambica Garments, 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

…e case of CIT vs. Metachem Industries 245 ITR 160. Hence, following the aforesaid precedents, we do not see any infirmity in the well reasoned order of the Ld. CIT(A), same is thereby upheld. ” (c) We further rely upon the decision of India Rice Mills v. CIT 218 ITR 508, 511 (All. HC) wherein it was held that where the capital contributions are made by the partners, it is for the partners to explain the source of such capital contributions and if they fail to discharge such onus then such capital contributions, although entered in the books of accounts of the assessee-firm, cannot be regarded as income of the as…

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, 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

…e case of CIT vs. Metachem Industries 245 ITR 160. Hence, following the aforesaid precedents, we do not see any infirmity in the well reasoned order of the Ld. CIT(A), same is thereby upheld. ” (c) We further rely upon the decision of India Rice Mills v. CIT 218 ITR 508, 511 (All. HC) wherein it was held that where the capital contributions are made by the partners, it is for the partners to explain the source of such capital contributions and if they fail to discharge such onus then such capital contributions, although entered in the books of accounts of the assessee-firm, cannot be regarded as income of the as…

Sunbond Ceramic Private Limited, Morbi vs. JCIT, Morbi Range, Morbi

In the result, appeal filed by the assessee is partly allowed, to the extent indicated above

ITA 739/RJT/2024[2014-15]Status: DisposedITAT Rajkot21 May 2025AY 2014-15

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.739/Rjt/2024 "नधा"रणवष" / Assessment Year: (2014-15)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav,Ld. Sr-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 40Section 44ASection 68

…nvested, by a particular person, be he a partner or an individual then the responsibility of the assessee is over. It is open to the A.O to undertake further investigation with regard to that individual who has deposited the amount. In India Rice Mills v. CIT 218 ITR 508, 511 (All.) it was held that where the capital contributions are made by the partners prior to the commencement of the business by the assessee-firm, it is for the partners to explain the source of such capital contributions and if they fail to discharge such onus then such capital ITA No.739/Rjt/2024 A.Y. 14-15 Sunbond Ceramic Pvt. Ltd. contrib…

Five Star Impex, Jaipur vs. ITO WD 4(2), Jpr, Jaipur

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

ITA 20/JPR/2025[2015-16]Status: DisposedITAT Jaipur24 Mar 2025AY 2015-16

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalfive Star Impex, F-939, Road No. 14R, Vki Area, Jaipur 302021 Pan No.:Aabff2606A ...... Appellant Vs. Income Tax Officer Ward-4(2), Jaipur ...... Respondent

For Appellant: Mr. S. B. Natani, C.A, Ld. ARFor Respondent: Mr. Arvind Kumar, Ld. CIT-DR
Section 144Section 145Section 250Section 250(5)Section 271(1)(c)Section 28Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “A”, JAIPUR BEFORE Dr. S. SEETHALAKSHMI, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER Five Star Impex, F-939, Road No. 14R, VKI Area, Jaipur 302021 PAN No.:AABFF2606A ...... Appellant Vs. Income Tax Officer Ward-4(2), Jaipur ...... Respondent Appellant by : Mr. S. B. Natani, C.A, Ld. AR Respondent by : Mr. Arvind Kumar, Ld. CIT-DR Date of hearing : 12/03/2025 Date of pronouncement : 24/03/2025 O R D E R PER GAGAN GOYAL, A.M: This appeal by assessee is directed against the order of NFAC, Delhi dated 23.11.2024 passed u/s. 250 of the Income Tax Act,…

Shri Dilip K Doshi, Mumbai vs. ITO Ward-42(1)(2), Mumbai

ITA 3018/MUM/2024[2009-10]Status: DisposedITAT Mumbai12 Sept 2024AY 2009-10

Bench: Shri. Prashant Maharshi & Shri. Sandeep Singh Karhail

For Appellant: Shri Dharmil Jhaveri, CAFor Respondent: Shri Akhatar Hussain Ansari, Sr. DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 145Section 147Section 148Section 250

…ilar cases. We relied on the following judgments of the higher forum :- • • • • • • • • • • • • PCIT vs. Mohommad Haji Adam (Bombay High Court) INCOME TAX APPEAL NO. 1004 OF 2016 dated 23/04/2019. ITO V/s Nityasudha Combines V/s ITA Chennai. Rice Mills Vs CIT 218 ITR 508, Allahabad High Court. CIT VS M Venkatesh Road and Others (2015) 370 ITR 215 Tamil Nadu and Andhra Pradesh High Court. M/s Fancy Wear V/s ITO Ward 24(3)(1), ITA No. 1596/1597/Mum/2016 dt. 20/09/2017. Shri Hiralal Chunilal Jain V/s ITO Ward 14(1)(4), ITA No. 4547/1275/Mum/2014 dt. 01/01/2016. M/s Ramesh Kumar & Co. v/s ACIT Ward 21(1), ITA No. 295…

Grr Holdings, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, all the three appeals filed by the assessee are allowed

ITA 195/HYD/2024[2017-18]Status: DisposedITAT Hyderabad24 Jul 2024AY 2017-18

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: : N O N E
Section 132(4)Section 153ASection 263Section 69A

…1 ITR 706 (All) and another in the case of Kapur Brothers [1979] 118 ITR 741 (All) were again up for consideration before a Division Bench of this court in the Page 33 of 42 ITA Nos 164, 194 and 195 of 2024 GRR Holdings case of India Rice Mill v. CIT (1996) 218 ITR 508. The relevant extract is reproduced below (page 510 of 218 ITR): "However, the Tribunal relying on CIT v. Kapur Brothers [1979] 118 ITR 741 (All), held that since the amount was credited in the books of the assessee-firm, it is for the assessee to explain the source of the deposits and as the assessee-firm failed to discharge that onus, the depos…

Grr Holdings, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, all the three appeals filed by the assessee are allowed

ITA 194/HYD/2024[2015-16]Status: DisposedITAT Hyderabad24 Jul 2024AY 2015-16

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: : N O N E
Section 132(4)Section 153ASection 263Section 69A

…1 ITR 706 (All) and another in the case of Kapur Brothers [1979] 118 ITR 741 (All) were again up for consideration before a Division Bench of this court in the Page 33 of 42 ITA Nos 164, 194 and 195 of 2024 GRR Holdings case of India Rice Mill v. CIT (1996) 218 ITR 508. The relevant extract is reproduced below (page 510 of 218 ITR): "However, the Tribunal relying on CIT v. Kapur Brothers [1979] 118 ITR 741 (All), held that since the amount was credited in the books of the assessee-firm, it is for the assessee to explain the source of the deposits and as the assessee-firm failed to discharge that onus, the depos…

Grr Holdings, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, all the three appeals filed by the assessee are allowed

ITA 164/HYD/2024[2014-15]Status: DisposedITAT Hyderabad24 Jul 2024AY 2014-15

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.164, 194 & 195/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2014-15,2015-16 & 2017-18) Grr Holdings Vs. Dy. C. I. T. Hyderabad Central Circle 3(3) Pan:Aaqfg0867M Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: N O N E सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 24/07/2024 आदेश/Order

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: : N O N E
Section 132(4)Section 153ASection 263Section 69A

…1 ITR 706 (All) and another in the case of Kapur Brothers [1979] 118 ITR 741 (All) were again up for consideration before a Division Bench of this court in the Page 33 of 42 ITA Nos 164, 194 and 195 of 2024 GRR Holdings case of India Rice Mill v. CIT (1996) 218 ITR 508. The relevant extract is reproduced below (page 510 of 218 ITR): "However, the Tribunal relying on CIT v. Kapur Brothers [1979] 118 ITR 741 (All), held that since the amount was credited in the books of the assessee-firm, it is for the assessee to explain the source of the deposits and as the assessee-firm failed to discharge that onus, the depos…

ITO, Ward-24(1), New Delhi vs. Sun Intrastate Pvt. Ltd., New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 1470/DEL/2023[2018-19]Status: DisposedITAT Delhi02 Jul 2024AY 2018-19

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Ms. Deepti Chandola, Sr. DR
Section 131Section 133(6)Section 142(1)Section 147Section 148Section 68

…the hands of the partners only and not in the case of the firm. This view of ours is supported by the decisions of the Hon’ble Allahabad High Court in the cases reported in CIT v. Jaiswal Motor Finance [1983] 141 ITR 706 and Surendra Mahan Seth v. CIT *1996 + 221 ITR 239.” ITA Nos. 1469 & 1470/Del/2023 14 Sun Intrastate Pvt. Ltd. Where the nature and source of a receipt, whether it be of money or other property, cannot be satisfactorily explained by the assessee, it is open for the revenue to hold that it is the income of the assessee and no further burden lies on the revenue to show that the income is from any…

ITO, Ward-24(1), New Delhi vs. Sun Intrastate Pvt. Ltd., New Delhi

In the result, the appeals of the Revenue are dismissed

ITA 1469/DEL/2023[2016-17]Status: DisposedITAT Delhi02 Jul 2024AY 2016-17

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Gautam Jain, Adv. &For Respondent: Ms. Deepti Chandola, Sr. DR
Section 131Section 133(6)Section 142(1)Section 147Section 148Section 68

…the hands of the partners only and not in the case of the firm. This view of ours is supported by the decisions of the Hon’ble Allahabad High Court in the cases reported in CIT v. Jaiswal Motor Finance [1983] 141 ITR 706 and Surendra Mahan Seth v. CIT *1996 + 221 ITR 239.” ITA Nos. 1469 & 1470/Del/2023 14 Sun Intrastate Pvt. Ltd. Where the nature and source of a receipt, whether it be of money or other property, cannot be satisfactorily explained by the assessee, it is open for the revenue to hold that it is the income of the assessee and no further burden lies on the revenue to show that the income is from any…

Aabhushan, Dhamnod, Madhya Pradesh vs. ITO Dhar, Dhar

In the result, appeal of the assessee is allowed

ITA 344/IND/2023[AY 2017-18]Status: DisposedITAT Indore09 May 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniaabhushan Dhamnod Ito, Dhar 1St Floor, Ganpati Market Ab Road Dhamnod Vs. Mp (Appellant / Assessee) (Respondent/ Revenue) Pan: Abgfa0812K Assessee By Shri Pranay Goyal & Shri S.N. Goyal, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.04.2024 Date Of Pronouncement 09.05.2024 O R D E R

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

…inor could not be prosecuted, has no substance. 21. It may be noted that the decision given in the case of Jaiswal Motor (supra) is being constantly followed by this court in the subsequent decisions. Reference can be made to Surendra Mohan Seth v. CIT [1996] 221 ITR 239 (All). 22. The Rajasthan High Court in CIT Vs. Kewal Krishna and Partners [2009] 18 DTR 121 (Raj) has also taken similar view." 27. Section 68 requires the Assessing Officer to satisfy itself of the source of the credit and if during the course of enquiry undertaken, the entries are found to be not genuine then the sum represented by such credit…

M/S Satwant Agro Engineers, Bhawanigarh vs. DCIT, Central Circle, Patiala

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

ITA 753/CHANDI/2022[AY 2019-20]Status: DisposedITAT Chandigarh03 May 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 115BSection 133ASection 143(2)Section 143(3)Section 68Section 69Section 69A

…gus shareholder, whose names are given to Assessing Officer, then the department is free to proceed to reopen their individual assessment in accordance to with law but it cannot be regarded as undisclosed income of assessee company. 5) India Rice Mills Vs CIT 218 ITR 508.-Credit in partners account should not assessed in firm. So the credit entry in partners account is not taxable in firm as income and should be assessed in individual partners account. If contention of surrendered letter is not acceptable to department, it should be treated as retreated from surrendered and unexplained amount/investment should be…

Clavecon India P.Ltd, Ghaziabad vs. DCIT, Central Circle, Ghaziabad

In the result both the appeals of the assessee in ITA Nos

ITA 1908/DEL/2022[2015-16]Status: DisposedITAT Delhi06 Oct 2023AY 2015-16

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri P.N. Barnwal, CIT- DR
Section 132Section 153ASection 69

…r Shishir Garg and not at the hands of Firm. 18. It may be noted that the decision given in the case of Jaiswal Motor Finance (supra) is being constantly followed by this Court in the subsequent decisions. Reference can be made to Surendra Mohan v. CIT [1996]221 ITR 239 (All.) 19. The Rajasthan High Court in CIT v. Kewal Krishna & Partners [2009] 18 DTR 121 has also taken similar view. 20. In view of the above, we are of the considered opinion that on the facts of the present case, the Tribunal was not justified in holding that the unexplained cash credit recorded in the assessee's book be added in the hands of…

Clavecon India P.Ltd, Ghaziabad vs. DCIT, Central Circle, Ghaziabad

In the result both the appeals of the assessee in ITA Nos

ITA 1907/DEL/2022[2014-15]Status: DisposedITAT Delhi06 Oct 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri P.N. Barnwal, CIT- DR
Section 132Section 153ASection 69

…r Shishir Garg and not at the hands of Firm. 18. It may be noted that the decision given in the case of Jaiswal Motor Finance (supra) is being constantly followed by this Court in the subsequent decisions. Reference can be made to Surendra Mohan v. CIT [1996]221 ITR 239 (All.) 19. The Rajasthan High Court in CIT v. Kewal Krishna & Partners [2009] 18 DTR 121 has also taken similar view. 20. In view of the above, we are of the considered opinion that on the facts of the present case, the Tribunal was not justified in holding that the unexplained cash credit recorded in the assessee's book be added in the hands of…

Smt. Rathnamma, Bangalore vs. Deputy Commissioner of Income-Tax, Central Circle-1(4), Bangalore

In the result, appeals of the assessee in ITA Nos

ITA 473/BANG/2023[2018-19]Status: DisposedITAT Bangalore13 Sept 2023AY 2018-19

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

For Appellant: Smt. Anitha R., A.RFor Respondent: Shri Nischal B., D.R
Section 132Section 153ASection 292CSection 68

…ot in the hands of the firm. The reasons given by the Tribunal are based on valid materials and evidence and hence the view taken by the Tribunal is in accordance with law. It is not a fit case for making addition under s. 68. -India Rice Mills vs. CIT (1996) 218 ITR 508 (All) and Surendra Mahan Seth vs. CIT (1996) 221 ITR 239 (All) concurred with; Jaqmohan Ram Ram Chandra vs. CIT (2005) 193 CTR (All) 153: (2005) 274 ITR 405 (All) distinguished.” ………………………………………………………………………………………. ITA Nos.468 to 473/Bang/2023 Smt. Rathnamma, Bangalore Page 8 of 10 12.3.1 Thus, the provision u/s 68 of the Income Tax Act, 1961 is…

Smt. Rathnamma, Bangalore vs. Deputy Commissioner of Income-Tax, Central Circle-1(4), Bangalore

In the result, appeals of the assessee in ITA Nos

ITA 472/BANG/2023[2017-18]Status: DisposedITAT Bangalore13 Sept 2023AY 2017-18

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

For Appellant: Smt. Anitha R., A.RFor Respondent: Shri Nischal B., D.R
Section 132Section 153ASection 292CSection 68

…ot in the hands of the firm. The reasons given by the Tribunal are based on valid materials and evidence and hence the view taken by the Tribunal is in accordance with law. It is not a fit case for making addition under s. 68. -India Rice Mills vs. CIT (1996) 218 ITR 508 (All) and Surendra Mahan Seth vs. CIT (1996) 221 ITR 239 (All) concurred with; Jaqmohan Ram Ram Chandra vs. CIT (2005) 193 CTR (All) 153: (2005) 274 ITR 405 (All) distinguished.” ………………………………………………………………………………………. ITA Nos.468 to 473/Bang/2023 Smt. Rathnamma, Bangalore Page 8 of 10 12.3.1 Thus, the provision u/s 68 of the Income Tax Act, 1961 is…

India Rice Mills v. CIT (218 ITR 508) — Cited in 37 Judgments | BharatTax