How many judgments cite Kale Khan Mohammad Hanif v. CIT?

581 judgments on BharatTax cite Kale Khan Mohammad Hanif v. CIT (50 ITR 1), spanning 2009 to 2026.

Which sections of the Income Tax Act does Kale Khan Mohammad Hanif v. CIT come up under?

It is most often cited in judgments turning on Section 68, Section 143(3), Section 115BBE, Section 69A, Section 147, Section 142(1).

Kale Khan Mohammad Hanif v. CIT

50 ITR 1Supreme Court of India1963#103 most cited

What is Kale Khan Mohammad Hanif v. CIT authority for?

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

581

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2009 to 2026.

Also referred to as

Kale Khan Mohammad Hanif v. CIT · Kale Khan 50 ITR 1 · onus of proof assessee · unexplained cash credits · Section 68 addition · source of money explanation · genuineness of transaction · creditworthiness of creditor · unexplained income · taxable receipts · burden of proof cash credits · Section 69A

Sections most often in play

Section 68 Section 143(3)Section 115BBE Section 69A Section 147 Section 142(1)Section 250 Section 148

Issues it is cited on

creditworthiness of the creditor onus of proof source of source share capital and share premium survey under section 133a addition u/s 68 addition under section 68 share application money genuineness of the transaction section 69b live link entry operator

Judgments citing Kale Khan Mohammad Hanif v. CIT

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

…urce and nature of certain amount of cash received during the accounting year, the Income-tax Officer is entitled to draw the inference that the receipts are of an assessable nature. In the case of Kale Khan Mohammad Hanif v. Commissioner of Income-tax [1963] 50 ITR 1 (SC)[08-02-1963] it is held by the Hon'ble Supreme Court as under- ‘’It seems to us that the answer to this question must be in the affirmative and that is how it was answered by the High Court. It is well established that the onus of proving the source of a sum of money found to have been received by the assessee is on him. If he disputes liability…

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

Sanjeev Kumar, Lucknow vs. Income Tax Officer-4(4), Lucknow

In the result, the appeal of the assessee is allowed

ITA 322/LKW/2025[2017-18]Status: DisposedITAT Lucknow04 Jun 2025AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 143(3)Section 69A

…rce of cash deposits in bank account is found to be satisfactory. The learned CIT(A), in his impugned appellate order, has referred to orders of Hon'ble Supreme Court in the case of Roshan Di Hatti vs. CIT 107 ITR 938 (SC) and Kale Khan Mohammad Hanif vs. CIT 50 ITR 1 (SC) for the view that when 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 to Revenue to hold that it is the income of the assessee. However, in the facts and circumstances of the present case, as discussed earlier, the explanation furnished by the assessee…

Nagar Panchayat, Banda vs. The Assisstant Commissioner of Income Tax Circle Sagar, Sagar

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

ITA 118/JAB/2024[2012-13]Status: DisposedITAT Jabalpur30 May 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2012-13 Nagar Panchayat, Banda, Vs. The Acit, Nagar Parishad Building, Banda, Sagar, Circle Sagar, Sagar Banda Nagar S.O. Madhya Pradesh Pan:Aaaln0246R (Appellant) (Respondent) Assessee By: Sh. Milind Wadhwani, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 19.05.2025 Date Of Pronouncement: 30.05.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 7.05.2024 Whereby The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Of The Dcit, Circle-Sagar, Madhya Pradesh Passed On 10.12.2019 Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961. The Grounds Of Appeal Are As Under:- “1. On The Facts & Circumstances Of The Case & In Law, The Ld. National Faceless Appeal Centre ('Nfac) Erred In Upholding The Action Of The Ld. Assistant Commissioner Of Income Tax Circle-Sagar ('Ao) In Adding A Sum Of Rs. 68,21,182/- To The Income Of The Assessee U/S. 69A As Unexplained Money. 2. On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 10.12.2019 Is Without Jurisdiction, Bad In Law & Liable To Be Quashed.3 3. On The Facts & Circumstances Of The Case & In Law, The Assessment Order Is Opposed To The Principles Of Equity, Natural Justice & Fair Play.

For Appellant: Sh. Milind Wadhwani, C.AFor Respondent: Sh. Alok Bhura, Sr. DR

Section 115BSection 133(6)Section 142(1)Section 147Section 148Section 271(1)(b)Section 69A

…IN THE INCOME TAX APPELLATE TRIBUNAL JABALPUR BENCH, JABALPUR (Through Virtual Mode) BEFORE SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER A.Y. 2012-13 Nagar Panchayat, Banda, vs. The ACIT, Nagar Parishad Building, Banda, Sagar, Circle Sagar, Sagar Banda Nagar S.O. Madhya Pradesh PAN:AAALN0246R (Appellant) (Respondent) Assessee by: Sh. Milind Wadhwani, C.A. Revenue by: Sh. Alok Bhura, Sr. DR Date of hearing: 19.05.2025 Date of pronouncement: 30.05.2025 O R D E R PER NIKHIL CHOUDHARY, A.M. This is an appeal filed by the assessee against the order of the ld. CIT(A), NFAC dated 7.05.202…

Navansh Vinimay Pvt. Ltd., Kolkata vs. I.T.O., Ward - 8(2), Kolkata

In the result, the appeal of the assessee is dismissed

ITA 724/KOL/2022[2012-2013]Status: DisposedITAT Kolkata30 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

…No.: 724/KOL/2022 Assessment Year: 2012-13 Navansh Vinimay Pvt. Ltd. has dealt with the issue from a legal perspective and some of the passages deserve to be extracted for reference: “This Court in the land mark case of Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 (SC) and, Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and creditworthiness, then the Assessing Officer must conduct an i…

Ashok Bricks Industries Private Limited, Belpahar R S vs. Asst Commissioner of Income Tax, Rourkela Circle

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

ITA 182/CTK/2025[2018-19]Status: DisposedITAT Cuttack26 May 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115JSection 143(3)Section 250Section 56(2)(viib)

…आयकर अपीलीय अधिकरण कटक पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL CUTTACK BENCH AT KOLKATA [वर्चुअल कोटु] [Virtual Court] श्री संजय शमाु, न्याधयक सदस्य एवं श्री राकेश धमश्रा, लेखा सदस्य के समक्ष Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT MEMBER I.T.A. No.: 182/CTK/2025 Assessment Year: 2018-19 Ashok Bricks Industries Private Asst. Commissioner of Limited Vs. Income Tax (Appellant) (Respondent) PAN: AADCA6930F Appearances: Assessee represented by : None (Adjournment appln. filed). Department represented by : S.C. Mohanty, Sr. DR. Date of concluding the hearing : May 14th,…

Kalubhai Maghabhai Bharvad Through Legal Heir Takhuben Bharvad, Anand vs. The ITO, Ward-1(3)(1), Petlad

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

ITA 2061/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad26 May 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Adjournment Application Filed (Sr. DR)

Section 147Section 69A

…essee/appellant failed to do the same both before the Assessing Officer and subsequently before the first Appellate Authority. Reliance is placed in this regard on the decision of the Hon'ble Supreme Court in the case of Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 wherein it was, held that "If an assessee fails to prove satisfactorily the source and nature of certain amount received during the accounting year, the Assessing Officer is entitled to draw the inference that the receipts are of an assessable nature". 8.2. In view of the above discussion, and bearing in mind the entirety of the case accompanied by…

Moonlink Marketing Pvt. Ltd., Kolkata vs. ITO, Ward-7(1), Kolkata

In the result, the appeal of the assessee is dismissed

ITA 215/KOL/2024[2012-13]Status: DisposedITAT Kolkata22 May 2025AY 2012-13

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 131Section 133(6)Section 144Section 250Section 68

…h normal banking channels, etc. In this case, the Hon'ble Apex Court has dealt with the issue from a legal perspective and some of the passages deserve to be extracted for reference: “This Court in the land mark case of Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 (SC) and, Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and creditworthiness, then the Assessing Officer must conduct an i…

Ajeet Kumar Rampuria, Tonk vs. ITO Ward 7(2), Tonk

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

ITA 44/JPR/2025[2013-14]Status: DisposedITAT Jaipur20 May 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sandeep Jhanwar, C.AFor Respondent: Sh. Anup Singh, Addl. CIT

Section 147Section 148Section 250

…ed, that evidence can be used against him by holding that it was a receipt of an income nature. The very words "an undisclosed source" show that the disclosure must come from the assessee and not from the Department". ii, Kale Khan Mohammad Hanif v CIT[1963] 50 ITR 1 (SC) "It is well established that the onus of proving the source of a sum of money found to have been received by the assessee is on him. If he disputes liability for tax, it is for him to show either that the receipt was not income or that if it was, it was exempt from taxation under the provisions of the Act. In the absence of such proof, the Inc…

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

…satisfactorily explained, and the business income estimated by him under section 13 of the Income-tax Act, after rejecting the books of account of the assessee as unreliable. This was so decided in Kale Khan Mohammad Hanif v. Commissioner of Income-tax [1963] 50 ITR 1 (SC). Whether in a given case the Income-tax Officer may tax the cash credit entered in the books of account of the business, and at the same time estimate the profit must, however, depend upon the facts of each case. ……………… The High Court, in disposing of the application under section 66(2), expressed the view that because the amount of Rs.20,000 w…

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

Kailash Chand Maheshwari, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 1463/JPR/2024[2015-16]Status: DisposedITAT Jaipur20 May 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 127Section 132Section 133ASection 144Section 153ASection 57Section 68Section 69C

DCIT-3(1), Bhopal vs. Manidhari Jewellers, Bhopal

The appeal are allowed

ITA 533/IND/2024[2017-18]Status: DisposedITAT Indore09 May 2025AY 2017-18

Bench: Bhagirath Mal Biyani & Shri Paresh M Joshidcit-3(1), Manidhari Jewellers, बनाम/ Bhopal Room No.202, Vs. Metro Walk Bulding, Bitten Market, Arera Colony, Bhopal (Pan: Abafm6546L) (Revenue) (Respondent) Assessee By Shri Yashwant Sharma, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 01.05.2025 Date Of Pronouncement 09.05.2025 आदेश/ O R D E R

Section 04Section 139Section 143(3)Section 147Section 148Section 24Section 25Section 250Section 253

…e entry from M/s R.B. Enterprises." 5.3.6 As per settled law, the initial onus is on the assessee to establish by cogent evidence the genuineness of the transaction under section 68. Hon'ble Supreme Court in the case of Kale Khan Mohammad Hanif Vs CIT [1963] 50 ITR 1(SC) and, Roshan Di Hatti Vs CIT [1977] ITR 938 (SC) laid down the onus of proving the source of a sum of money found to have been received by the assessee, is on the assessee. Once the assesse has submitted the documents relating to the genuineness of the transaction, then AO must conduct inquiry, and call for more detail before invoking provisions…

Rudramukhi Vintrade Ltd., Kolkata vs. A.C.I.T., Circle - 11(1), Kolkata

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

ITA 2317/KOL/2024[2013-2014]Status: DisposedITAT Kolkata07 May 2025AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 148Section 250

…f the accommodation entry provider was not considered necessary by the Ld. CIT(A). The Ld. CIT(A) has also considered the judicial pronouncements in the cases mentioned below: i) CIT v. P. Mohanakala 291 ITR 278 (SC) ii) Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 (SC) iii) Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) iv) CIT Vs Durga Prasad More (1971) 82 ITR 540 (SC) I.T.A. No.: 2317/KOL/2024 Assessment Year: 2013-14 Rudramukhi Vintrade Ltd. 4.1 The Ld. CIT(A) accordingly concluded as under: “7.4 It is therefore obligatory on the part of the assessee that it explains the nature and source of credits in it…

Shree Durga Jewellers, Jawahar Nagar Jaipur vs. AO Circle 4 Jaipur, Cr Building Jaipur

In the result, the appeal of the assessee is allowed

ITA 33/JPR/2025[2017-18]Status: DisposedITAT Jaipur29 Apr 2025AY 2017-18

For Appellant: Shri Suhani Meharwal, CAFor Respondent: Shri Anup Singh, Addl. CIT

Section 143(1)Section 143(2)Section 143(3)Section 68

…spute, i.e., if any sum is found credited in the books of account of an assessee, the onus is on assessee to explain the said entry. 8.13 Even before the enactment of Section 68, this rule of evidence was applicable vide Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC). Section 68 does not absolve the responsibility of the Assessing Officer to prove that the cash credits constitute the income of the assessee. In the present case proper enquiries have been conducted by the Assessing Officer before making addition. Further appellant also failed to satisfy the Assessing Officer with its explanation/justification…

Gopal Extrusions Pvt Ltd, Jalgaon vs. Income-Tax Officer, Ward - 1(2), Jalgaon

ITA 1633/PUN/2017[2008-09]Status: DisposedITAT Pune29 Apr 2025AY 2008-09

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1633/Pun/2017 Assessment Year : 2008-09

For Appellant: Smt. Deepa KhareFor Respondent: Shri Ramnath Murkunde

Section 143(3)

…y as referred to in clause (23FB) of section 10.” 16. From going through the above provision, the initial burden is to be discharged by the assessee to explain the nature and source. Hon’ble Apex Court in the case(s) of Kale Khan Mohammed Hanif v. CIT [1963] 50 ITR 1 (SC) and Roshan Di Hatti v. CIT [1977] 107 ITR 938 (SC) laid down the proposition that the onus of proving the source of a sum of money found to have been received by an assessee, is on the assessee. Once the assessee has submitted the documents relating to identity, genuineness of the transaction, and credit-worthiness, then the AO must conduct an…

Kath Brothers, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, the appeal of the assessee is allowed

ITA 77/JPR/2025[2019-20]Status: DisposedITAT Jaipur28 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 115BSection 133ASection 143(2)Section 143(3)Section 145(3)Section 234ASection 69

…satisfactorily explained, and the business income estimated by him under section 13 of the Income-tax Act, after rejecting the books of account of the assessee as unreliable. This was so decided in Kale Khan Mohammad Hanif v. Commissioner of Income-tax [1963] 50 ITR 1 (SC). Whether in a given case the Income-tax Officer may tax the cash credit entered in the books of account of the business, and at the same time estimate the profit must, however, depend upon the facts of each case. ……………. The High Court, in disposing of the application under section 66(2), application expressed the view that because the amount o…

Meenamani Ganga Builder LLP, Pune vs. PCIT (Central), Pune

In the result, the appeal of the assessee is dismissed

ITA 1027/PUN/2024[2019-20]Status: DisposedITAT Pune21 Apr 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1027/Pun/2024

Section 132Section 143(2)Section 143(3)Section 153DSection 263Section 263(1)Section 68

…the AO. In the assessment order also, the discussion is only with regard to the on-money transactions found during the course of search. At this juncture, we would like to take note of the Hon'ble Apex Court in the case of Kale Khan Mohd. Hanif Vs. CIT (1963) 50 ITR 1 where the Hon'ble Court laid down the proposition with regard to examination of nature and source of cash credit u/s.68 and Hon'ble Court held that three limbs needs to be examined, namely Identity of the cash creditor, creditworthiness of the cash creditor and genuineness of the transaction. Now in the instant case, merely confirmation letters have…

Jayanthi Rajagounder, Chennai vs. ITO, Ncw-19(4), Chennai

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

ITA 3146/CHNY/2024[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 3146/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Smt. Jayanthi Rajagounder, The Income Tax Officer, No.F-1, First Floor, V. Non-Corporate Ward 19(4), Seenivasam Flat No.9, Chennai - 34. Durairaj Street, Palavanthangal, Chennai – 600 061. [Pan:Ahspj 9904F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri K.B. Muralidharan, Ca ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तार"ख/Date Of Hearing : 26.02.2025 घोषणा क" तार"ख/Date Of Pronouncement : 17.04.2025 आदेश /O R D E R

For Appellant: Shri K.B. Muralidharan, CAFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 115BSection 69A

…ion period. Hence the entire cash deposits are to be treated as unexplained money/investments. 8.1 As enumerated in the decision of the Hon'ble Supreme Court in the case of Roshan Di Hatti Vs CIT (1977) 107 ITR 938 (SC), Kale Khan Mohammed Hanif Vs CIT (1963) 50 ITR 1 (SC), it has been held in various judicial pronouncement that where the nature and source of any receipt/investment, whether it be a 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…

Pankaj Mani Kulshreshtha, Jaipur vs. ITO, Ward-3(5), Jaipur

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

ITA 19/JPR/2025[2017-18]Status: DisposedITAT Jaipur27 Mar 2025AY 2017-18

Bench: The Hearing.”

For Appellant: Shri Vikash Yadav, AdvocateFor Respondent: Sh. Gautam Singh Choudhary, Addl.CIT a

Section 143(3)Section 250(6)

…pondent-assessees, who are parties to connected civil appeals herein. Accordingly. the above civil appeals filed by the Department are allowed with no order as to costs. Further the following decision in the case of Kale Khan Mohammad Hanif vs CIT reported in 50 ITR 1 The exposition of the Hon'ble Apex Court is as under :- "It is well established that the onus of proving the source of a sum of money found to have been received by the assessee is on him. If he disputes liability for tax, it is for him to show either that the receipt was not income or that if it was, it was exempt from taxation under the provisions…