PCIT v. Ambe Tradecorp Pvt. Ltd.

145 Taxmann.com 27High Court2022#574 most cited

What is PCIT v. Ambe Tradecorp Pvt. Ltd. authority for?

No addition under section 68 can be made for a loan if the assessee furnishes material proving the identity of the loan givers, demonstrates they are not the beneficial owner, and has repaid the loan in a subsequent year.

169

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2023 to 2026.

Also referred to as

PCIT v. Ambe Tradecorp Pvt. Ltd. · Ambe Tradecorp · section 68 · cash credit addition · unexplained cash credit · identity of creditor · creditworthiness · genuineness of transaction · onus discharge · loan repayment · beneficial owner · section 133(6)

Issues it is cited on

Judgments citing PCIT v. Ambe Tradecorp Pvt. Ltd.

Amigos Prasasth Path Social Welfare Society, Kolkata vs. CIT(Exemption), Kolkata

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1501/KOL/2025[---]Status: DisposedITAT Kolkata27 Oct 2025

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1500 & 1501/Kol/2025 Amigos Prasasth Path Social Welfare Society.……….……….……….……Appellant 1 Ram Krishna Bagchi Lane, Beadon Street, Battala, Kol- 700006.. [Pan: Aajta7599P] Vs. Cit (Exemption), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Giridhar Dhelia, Advocate, Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 08, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Both Dated 28.06.2025 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(E)’] Rejecting The Separate Applications Filed In Form 10Ab For Final Approval As Per The Provisions Of Sections 12A(1)(Ac)(Iii) & 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since Both The Appeals Relate To The Same Assessee & Arise From The Final Registration U/S 12A Of The Act Which Is Compulsory For Getting Subsequent Registration U/S 80G Of The Act Which Are Interconnected In Both The Appeals & Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. Ita No.1500/Kol/2025 Is Taken As Lead Case For Narration Of Facts.

Section 12ASection 12A(1)(ac)Section 80G

…आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Rajesh Kumar, Accountant Member and Shri Pradip Kumar Choubey, Judicial Member ITA Nos.1500 & 1501/Kol/2025 Amigos Prasasth Path Social Welfare Society.……….……….……….……Appellant 1 Ram Krishna Bagchi Lane, Beadon Street, Battala, Kol- 700006.. [PAN: AAJTA7599P] vs. CIT (Exemption), Kolkata………………………………….....……...…..…..Respondent Appearances by: Shri Giridhar Dhelia, Advocate, appeared on behalf of the appellant. Shri Raja Sengupta, CIT- DR, appeared on behalf of the Respondent. Date of concluding the hearing :…