P.V. Raghdva Reddi v. CIT

29 ITR 942Reported decision1956#9640 most cited

What is P.V. Raghdva Reddi v. CIT authority for?

The assessee bears the burden of satisfactorily explaining the source and nature of cash receipts, even if credited in a third party's name. The Income-tax Officer can infer receipts are assessable if this burden is not discharged.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2019 to 2025.

Also referred to as

P.V. Raghdva Reddi v. CIT · 29 ITR 942 · onus of proof · source of cash credits · nature of cash credits · unexplained cash credits · addition under section 68 · burden of explanation · section 145(3) · section 68

Sections most often in play

Section 68Section 144Section 145(3)Section 153ASection 153DSection 250Section 269SSSection 271(1)(c)

Issues it is cited on

section 155bbesection 2(9)section 66onus of proofsection 155section 269sssurvey under section 133asection 271dsection 269section 132(4a)addition under section 68section 44ad

Judgments citing P.V. Raghdva Reddi v. CIT

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

…see fails to prove satisfactorily the source and nature of certain amounts 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 P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Ot…

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

…see fails to prove satisfactorily the source and nature of certain amounts 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 P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Ot…

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

…see fails to prove satisfactorily the source and nature of certain amounts 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 P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Ot…

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

…see fails to prove satisfactorily the source and nature of certain amounts 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 P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Ot…

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

…see fails to prove satisfactorily the source and nature of certain amounts 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 P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Ot…

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

ITA 56/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Oct 2025AY 2014-15
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT
Section 153ASection 250Section 68

…see fails to prove satisfactorily the source and nature of certain amounts 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 P.V. Raghdva Reddi v. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shift to the Income-tax Officer under certain circumstances. Ot…

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

…) observed that the language of section 68 shows that it is general in nature and applies to all credit entries in whomsoever name they may stand, that is, whether in the name of the assessee or a third party. In the case of P.V. Raghava Reddi vs. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in ITA Nos. 1469 & 1470/Del/2023 13 Sun Intrastate Pvt. Ltd. the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shif…

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

…) observed that the language of section 68 shows that it is general in nature and applies to all credit entries in whomsoever name they may stand, that is, whether in the name of the assessee or a third party. In the case of P.V. Raghava Reddi vs. CIT [1956] 29 ITR 942, it was observed by the Andhra Pradesh High Court that the burden of proof is not dependent upon the fact of a credit entry in the name of the assessee or in ITA Nos. 1469 & 1470/Del/2023 13 Sun Intrastate Pvt. Ltd. the name of a third party. In either case, the burden lies upon the assessee to explain the credit entry, though the onus might shif…

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S. Agrasen Agro Industries Private Limited, Kota

ITA 1205/JPR/2018[2011-12]Status: DisposedITAT Jaipur27 Mar 2019AY 2011-12
Section 143(3)Section 153Section 153ASection 68

…e, the respective Lenders duly complied with the notices under Section-131 and/or Section-133 of the Act. Thus, considering the ratio laid down by the Hon’ble Court the invoking of Section-68 by the Ld. AO is unlawful. (viii) P.V. Raghava Reddy V. CIT (1956) 29 ITR 942 and M.M. A.K. Mohindeen Thambay & Co. V. CIT (1959) 36 ITR 481: The aforesaid cases, relied upon by the Ld. AO have no relevancy to the case of Appellant. In this case the Hon’ble Court held that the question of burden of proof cannot be made to depend exclusively upon the fact of a credit entry in the name of the assessee or in the name of a thir…

Deputy Commissioner of Income Tax, Central Circle, Kota vs. M/S. Agrasen Agro Industries Private Limited, Kota

ITA 1188/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…e, the respective Lenders duly complied with the notices under Section-131 and/or Section-133 of the Act. Thus, considering the ratio laid down by the Hon’ble Court the invoking of Section-68 by the Ld. AO is unlawful. (viii) P.V. Raghava Reddy V. CIT (1956) 29 ITR 942 and M.M. A.K. Mohindeen Thambay & Co. V. CIT (1959) 36 ITR 481: The aforesaid cases, relied upon by the Ld. AO have no relevancy to the case of Appellant. In this case the Hon’ble Court held that the question of burden of proof cannot be made to depend exclusively upon the fact of a credit entry in the name of the assessee or in the name of a thir…

M/S. Agrasen Agro Industries Private Limited, Kota vs. Deputy Commissioner of Income Tax, Central Circle, Kota

ITA 1053/JPR/2018[2010-11]Status: DisposedITAT Jaipur27 Mar 2019AY 2010-11
Section 143(3)Section 153Section 153ASection 68

…e, the respective Lenders duly complied with the notices under Section-131 and/or Section-133 of the Act. Thus, considering the ratio laid down by the Hon’ble Court the invoking of Section-68 by the Ld. AO is unlawful. (viii) P.V. Raghava Reddy V. CIT (1956) 29 ITR 942 and M.M. A.K. Mohindeen Thambay & Co. V. CIT (1959) 36 ITR 481: The aforesaid cases, relied upon by the Ld. AO have no relevancy to the case of Appellant. In this case the Hon’ble Court held that the question of burden of proof cannot be made to depend exclusively upon the fact of a credit entry in the name of the assessee or in the name of a thir…

P.V. Raghdva Reddi v. CIT (29 ITR 942) — Cited in 11 Judgments | BharatTax