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“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

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.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull
87 ITR 349 · 1973 · Supreme Court
525
citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT
107 ITR 938 · 1977 · Supreme Court
477
citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.
208 ITR 465 · 1994 · High Court
427
citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT
172 ITR 250 · 1988 · Supreme Court
340
citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Central Circle 1(1) Ahmedabad, Ahmedabad vs. Sunit Sudhirbhai Chokshi, Ahmedabad

In the result, the appeals filed by the Revenue are hereby dismissed

ITA 1475/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad13 Dec 2024AY 2018-19

Bench: Ld. Cit(A) On The Quantum Addition, Wherein Ld. Cit(A) Confirmed The Addition To Rs.4,71,46,684/- Only. Thus The Assessing Officer Levied Penalty Of Rs.2,80,88,610/- Being 60% Of Addition Confirmed By Ld. Cit(A) U/S. 271Aab Of The Act.

Section 143(3)Section 271ASection 69ASection 69C

ITAT has of unexplained has confirmed deleted the addition. expenditure u/s 69C addition on this ground. 6. Unexplained money 45,24,000 The Ld. CIT(A) The Ld. ITAT has u/s 69A has restricted confirmed addition the addition at amounting to Rs.16,40,000/- Rs.16,40,000/- on this ground

DCIT Central Circle 1(1), Ahmedabad vs. Sunit Sudhirbhai Chokshi, Ahmedabad

In the result, the appeals filed by the Revenue are hereby dismissed

ITA 1474/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad13 Dec 2024AY 2017-18

Bench: Ld. Cit(A) On The Quantum Addition, Wherein Ld. Cit(A) Confirmed The Addition To Rs.4,71,46,684/- Only. Thus The Assessing Officer Levied Penalty Of Rs.2,80,88,610/- Being 60% Of Addition Confirmed By Ld. Cit(A) U/S. 271Aab Of The Act.

Section 143(3)Section 271ASection 69ASection 69C

ITAT has of unexplained has confirmed deleted the addition. expenditure u/s 69C addition on this ground. 6. Unexplained money 45,24,000 The Ld. CIT(A) The Ld. ITAT has u/s 69A has restricted confirmed addition the addition at amounting to Rs.16,40,000/- Rs.16,40,000/- on this ground

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Periyasamy Saravanan, Karur

In the result, all the appeals of the Revenue and all the COs of

ITA 1247/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Rajesh Kumar, Chennai

In the result, all the appeals of the Revenue and all the COs of

ITA 1245/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

DCIT, Central Circle 2(3), Chennai vs. Sivasubramanian, Karur

In the result, all the appeals of the Revenue and all the COs of the assessee are dismissed

ITA 1243/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.1208/Chny/2024 & C.O.No.35/Chny/2024 (In Ita No.1208/Chny/2024) िनधा"रण वष"/Assessment Year:2018-2019. The Assistant Commissioner P. Selvaraj, Of Income Tax, Vs. 5/68,Kurumbapatty, Central Circle 2, Pavithram Po Trichy Karur 639 002. Pan: Boips 1370G Respondent/Cross Objector Appellant आयकर अपील सं./Ita No.1212/Chny/2024 & C.O.No.36/Chny/2024 (In Ita No.1212/Chny/2024) िनधा"रण वष"/Assessment Year:2018-2019. The Assistant Commissioner K.N. Prabhu, Of Income Tax, Vs. 23, Bharathi Nagar, Central Circle 2, Karur 639 002 Trichy Pan: Aczpp 6832G Appellant Respondent/Cross Objector

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Sellappagounder Ramasamy Karthic, Karur

In the result, all the appeals of the Revenue and all the COs of

ITA 1242/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Palaniappan Sekar, Karur

In the result, all the appeals of the Revenue and all the COs of

ITA 1241/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. K.N.Prabhu, Karur

In the result, all the appeals of the Revenue and all the COs of the assessee are dismissed

ITA 1212/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.1208/Chny/2024 & C.O.No.35/Chny/2024 (In Ita No.1208/Chny/2024) िनधा"रण वष"/Assessment Year:2018-2019. The Assistant Commissioner P. Selvaraj, Of Income Tax, Vs. 5/68,Kurumbapatty, Central Circle 2, Pavithram Po Trichy Karur 639 002. Pan: Boips 1370G Respondent/Cross Objector Appellant आयकर अपील सं./Ita No.1212/Chny/2024 & C.O.No.36/Chny/2024 (In Ita No.1212/Chny/2024) िनधा"रण वष"/Assessment Year:2018-2019. The Assistant Commissioner K.N. Prabhu, Of Income Tax, Vs. 23, Bharathi Nagar, Central Circle 2, Karur 639 002 Trichy Pan: Aczpp 6832G Appellant Respondent/Cross Objector

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. P.Selvaraj, Karur

In the result, all the appeals of the Revenue and all the COs of

ITA 1208/CHNY/2024[2018-19]Status: DisposedITAT Chennai13 Dec 2024AY 2018-19

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunatha

Section 132Section 153C

firm during the appellate proceedings. 3 The Ld.CIT(A) erred in holding that the amount of deposit made would not fetch the character of unexplained money u/s.69A of the Act, without appreciating that the amount of deposit made by the assessee is out of the unexplained money in his possession ... made in the FY 2017-18 c. The Hon’ble CIT(A) has been correct in holding that the “deposit amount” cannot fall under “unexplained money” as held by the Hon’ble Supreme Court. 3. Prayer For the above grounds, and any other grounds that may be adduced during appellate

Alok Vijawat, Jaipur vs. PCIT, Udaipur

ITA 605/JPR/2024[2019-20]Status: DisposedITAT Jaipur13 Dec 2024AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Devang Gargieya, AdvocateFor Respondent: Ms. Alka Gautam, CIT-DR
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 263

should have been charged u/s 69 as Unexplained Investment for Rs.66,50,000 (45,50,000 +21,00,000), AND, Rs.9,50,000/- (Unexplained Money) should have been charged u/s 69A of the Act and hence, the tax should have been charged u/s 115BBE of the I.T. Act, 1961, which ... Undisclosed 45,50,000/- Debtors being To be tax @ debtors undisclosed income u/s 60% u/s 69 115BBE 2. Excess Cash 9,50,000/- Unexplained Money u/s To be tax @ Found 69A 60% u/s 115BBE 3. Unaccounted 21,00,000/- Unexplained To be tax @ Construction Expenditure u/s 69C 60% u/s 115BBE

Sh. Taiyab Khan, Jaipur vs. The Asstt. Commissioner of Income Tax, Alwar

ITA 342/JPR/2024[2017-18]Status: DisposedITAT Jaipur13 Dec 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Tarun Mittal (C.A.)For Respondent: Shri Anup Singh (Addl.CIT)
Section 115BSection 133ASection 142(1)Section 143(2)Section 143(3)Section 288ASection 4Section 44ASection 68Section 69A

assessee partly allowed the appeal deleting the addition of expenditure, but while doing the ld. CIT(A) has enhanced the addition on account of unexplained money being the difference of money found and available in the books of account. The finding of the ld. CIT(A) on the issue which ... such expenses and made an addition of Rs. 6,78,666 in this regard. As addition on account of unexplained cash credits / unexplained money has already been sustained and enhanced in the pre- paragraphs, the separate addition on account of unverifiable/unexplained cash expenses is not required as conceptually the unaccounted

Lachman Das Bhatia Hingwala (P) Ltd, Delhi vs. Income Tax Officer, Ward-15(1), Delhi

Appeal is allowed

ITA 2271/DEL/2024[2017-18]Status: DisposedITAT Delhi13 Dec 2024AY 2017-18
Section 115BSection 143(3)Section 234BSection 292BSection 68

facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in treating the addition made as unexplained money by Ld. AO u's 69A as unexplained deposits u's 68 by holding that the quoting of wrong section is a curable mistake u/s 292B

Pramod Kumar Rustagi, New Delhi vs. ACIT Central Circle 20, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 1608/DEL/2023[2019-20]Status: DisposedITAT Delhi13 Dec 2024AY 2019-20

Bench: Shri M. Balaganesh & Shri Vimal Kumarpramod Kumar Rustagi Vs. Acit C/O. Advocate Kanika Jain Central Circle – 20 D-80, Lgf, New Delhi Panchsheel Enclave, New Delhi – 110 017 Pan : Aaepr 2763 D (Appellant) (Respondent) Assessee By Shri K. Sampath, Adv. & Shri V. Rajakumar, Adv. Respondent By Ms. Anu Krishna Agarwal, Cit-D.R. Date Of Hearing 10.10.2024 Date Of Pronouncement 13.12.2024 O R D E R Per Vimal Kumar, Jm:

Section 127Section 132Section 132(1)Section 142(1)Section 143(3)Section 68Section 69A

that if explanation offered by the assessee regarding source of money, bullion, jewellery or other valuable articles is satisfactory, it cannot be treated as unexplained money under Section 69A of the Act. In the facts of the present appeal, there is nothing on record to suggest that assessee’s explanation

Shalabh Kumar Goel, Delhi vs. DCIT, Central Circle-7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 2605/DEL/2022[2016-17]Status: DisposedITAT Delhi13 Dec 2024AY 2016-17

Bench: Shri Vikas Awasthy & Smt. Renu Jauhri[Assessment Year : 2016-17] Shri Shalabh Kumar Goel, Vs Dcit, D-72, Delhi Citizen Apartment, Central Circle-7, Sector-13, Near D.C.Chowk, New Delhi. Rohini, New Delhi-110085. Pan-Amkpg9295R Appellant Respondent Appellant By Shri Gautam Jain, Adv. & Shri Parth Singhal, Adv. Respondent By Ms. Jaya Chaudhary, Cit Dr Date Of Hearing 02.12.2024 Date Of Pronouncement 13.12.2024

Section 145(3)Section 153CSection 153DSection 234ASection 234BSection 65BSection 69A

Income Tax (Appeals) has further erred both in law and on facts in upholding an addition of Rs. 26,60,000/- representing alleged unexplained money and brought to tax u/s 69A of the Act. 3.1. That while confirming the above addition, the learned Commissioner of Income Tax (Appeals) has failed ... premises of a third party in absence of corroborative evidence could not be ipso-facto a ground or basis to assume that there is unexplained money taxable in the hand of appellant u/s 69A of the Act. 5.2. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate

Rajesh Kumar Gupta, Pilibhit vs. ITO Range-2(4), Pilibhit

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

ITA 583/LKW/2024[2018-19]Status: DisposedITAT Lucknow12 Dec 2024AY 2018-19

Bench: Shri Anadee Nath Misshrarajesh Kumar Gupta V. The Income Tax Officer Range-2(4), Mohalla- Bakhtavar Lal Baraha Patthar Chauraha Wale, The Assessment Unit Income Tax Department Bisalpur, Pilibhit-262001. Nfac, New Delhi Pan:Arlpr2101H (Appellant) (Respondent) Appellant By: Shri K. R. Rastogi Respondent By: Shri Sunil Kumar Rajwanshi, Addl. Cit(Dr) O R D E R

For Appellant: Shri K. R. RastogiFor Respondent: Shri Sunil Kumar Rajwanshi, Addl
Section 144BSection 147Section 148Section 250Section 69A

point out any discrepancies in supporting evidences, made the addition of Rs. 2,75,693/- treating as Excess Credit in Bank Account as unexplained money w/e 69A of I. T. Act. 4. The Ld. C.I.T. (A) failed to appreciate that Ld. A. O. has not pointed out any defect ... excess credit of Rs. 6,12,682/-. You are therefore, show-caused as to why the excess credit should not be treated as unexplained money and added to your total income for the AY under consideration. For both the queries, the Appellant in his reply dt 19.03.2023, submitted full explanation

ITO, W-1(3), Chandigarh vs. Smt. Renu Anand, Chandigarh

ITA 1353/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh12 Dec 2024AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Samir Mahajan, CA and Shri Surinder Mahajan, CAFor Respondent: Smt. Kusum Bansal, CIT, DR
Section 142(1)Section 143(2)Section 253

deemed income from undisclosed sources under the provisions of section 69 of the IT. Act. The balance amount of Rs.5,17,50,000/-is unexplained money in the hands of the assessee and is treated as deemed income of the assessee from undisclosed sources by invoking the provisions of section

Somnath Kelavni Mandal, Nadiad vs. Income Tax Officer, Ward Exemption-Baroda

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

ITA 937/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad12 Dec 2024AY 2017-18

Bench: Dr. BRR Kumar (Vice President), Shri TR Senthil Kumar (Judicial Member)

For Appellant: NoneFor Respondent: Shri Rignesh Das, Sr. D.R
Section 144Section 69A

matching with the cash book maintained by the assessee. Thus, the A.O. made the cash deposit of Rs. 51,17,000/- as unexplained money u/s. 69A of the Act and demanded tax thereon. 3. Aggrieved against the assessment order, the assessee filed appeal before CIT(A) who has given five

Shri Santosh Harichand Katrela, Beed vs. Income-Tax Officer, Ward -1, Beed

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

ITA 339/PUN/2021[2017-18]Status: DisposedITAT Pune12 Dec 2024AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.339/Pun/2021 िनधा"रण वष" / Assessment Year : 2017-18 Shri Santosh Harichand Vs. Ito, Ward-1, Beed. Katrela, Audut Campus, Jalna Road, Gujrathi Colony Beed, Beed- 431122. Pan : Akgpk6862N Appellant Respondent Assessee By : Smt. Deepa Khare Revenue By : Shri Arvind Desai Date Of Hearing : 13.11.2024 Date Of Pronouncement : 12.12.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.03.2021 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2017-18. 2. Registry Has Pointed Out That The Appeal Is Filed With Delay Of 99 Days. In The Light Of The Fact That Due To Covid-19 Pandemic The Period Of Limitation Has Already Been Extended By Hon’Ble Supreme

For Appellant: Smt. Deepa KhareFor Respondent: Shri Arvind Desai
Section 115BSection 143(2)Section 143(3)Section 250Section 68Section 69Section 69A

that the above amount was accepted by the assessee after declaration of demonetization hence the above amount of Rs.4,74,000/- is treated as unexplained money and added to the total income of the assessee 4 u/s 69A r.w.s. 115BBE in view of second amendment to section 115BBE made through ... Rs.14,72,290/- as against the income returned by the assessee at Rs.9,98,290/-. The above assessed income includes Rs.4,74,000/- as unexplained money u/s 69A of the IT Act. 5. In first appeal, after considering the reply of the assessee, Ld. CIT(A)/NFAC dismissed the appeal

Vikram Agrawal, Nagpur vs. ITO Ward 4(4), Nagpur

In the result, appeal is dismissed

ITA 321/NAG/2023[2017 18]Status: DisposedITAT Nagpur12 Dec 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

Vikram Agrawal, Nagpur vs. ITO Ward 4 (4), Nagpur

In the result, appeal is dismissed

ITA 320/NAG/2023[2016 17]Status: DisposedITAT Nagpur12 Dec 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 147Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY