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“Commissioner (Appeals)”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(16A) / Section 1174,761 judgments

The decision most relied on for Commissioner (Appeals) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Commissioner (Appeals)

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)
297 CTR 614 · 2017 · High Court
659
citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Ahmedabad Electricity Co. Ltd. v. CIT
199 ITR 351 · 1993 · High Court
441
citing judgments

Appellate authorities can consider additional grounds for deduction, even if not originally claimed before the Assessing Officer or Appellate Assistant Commissioner, provided the facts are not disputed and it pertains to a legal claim for correct tax liability. This is because the purpose of an appeal is to ascertain the correct tax liability.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

CIT v. Shapoorji Pallonji Mistry
44 ITR 891 · 1962 · Supreme Court
278
citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Mahindra and Mahindra Ltd. v. DCIT
30 SOT 374 · 2009 · ITAT
201
citing judgments

The Commissioner of Income Tax (Appeals) cannot expand the scope of an assessment or improve the Assessing Officer's case in a manner that usurps the revisional power of the Commissioner of Income Tax under Section 263 of the Income-tax Act.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.
56 Taxmann.com 286 · 2015 · High Court
196
citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Judgments citing Commissioner (Appeals)

Dy. Commissioner of Income Tax Central Circle-I Noida, Noida vs. M/S Rudra Buildwell Homes Pvt. Ltd., Delhi

Accordingly, all the grounds of appeal taken by Revenue are dismissed

ITA 4119/DEL/2025[2022-23]Status: DisposedITAT Delhi24 Dec 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwaldy. Cit, M/S Rudra Buildwell Homes Central Circle-I, Private Limited, Noida-201301, Vs. D-53, Okhla, Phase-1, Uttar Pradesh. Delhi-110020. Pan-Aafcr6959P (Appellant) (Respondent) Dy. Cit, M/S Rudra Buildwell Projects Central Circle-I, Private Limited, Noida-201301, Vs. D-53, Okhla, Phase-1, Uttar Pradesh. Delhi-110020. Pan-Aaecr9589E (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 41(1)

cannot partake the character of additional evidence as per Rule-46A(4) Nothing contained in this rule shall affect the power of the (Joint Commissioner) (Appeals)] (or, as the case may be, the Commissioner (Appeals)] to direct the production of any document, or the examination of any witness, to enable ... resident involved in retail business in USA, with Canara Bank and addition was made under section 698 based on unexplained investment in time deposits - Commissioner (Appeals) carried out an inquiry in DCIT vs. M/s Rudra Buildwell Homes Private Limited & Ors. matter by exercising his powers under section

Hiteshbhai Rameshbhai Patel, Surat vs. ITO Ward, 2, Bardoli

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

ITA 484/SRT/2025[2012-13]Status: DisposedITAT Surat23 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-13 Hiteshbhai Rameshbhai Patel Income Tax Officer, 466 Kanbivad, Goddha Mahuwa, Ward-2, Bardoli, Income Tax Taluka Valod, Dist. Surat 394630 Vs. Office, 2Nd Floor, Bsnl Gujarat, Building, Opp. Jalaram Temple, Station Road, Bardoli- 394601 Pan No. Avdpp 6788 Q Appellant Respondent Assessee By : Mr. Sakar Sharma, Ar Revenue By : Mr. J.K. Chandani, Sr-Dr

For Appellant: Mr. Sakar Sharma, ARFor Respondent: Mr. J.K. Chandani, Sr-DR
Section 143(3)Section 147Section 148Section 151(1)Section 68

revenue records in Form No. 7/12 and 8A evidencing ownership of agricultural land, certificates relating to sugarcane cultivation, and other supporting documents. The Commissioner (Appeals) called for a remand report from the Assessing Officer. 3.1 In the remand report, the Assessing Officer did not accept the assessee‟s explanation ... support of the claim of agricultural income. Upon consideration of the material on record and the Hiteshbhai Rameshbhai Patel 4 remand report, the Commissioner (Appeals) rejected the assessee‟s contentions and dismissed the appeal. 3.2 Being aggrieved by the order of the Commissioner (Appeals), the assessee is now in appeal

Sanjay Mukati, Indore vs. Income Tax Officer-2(1), Main Building Indore

Appeal is allowed for statistical purpose

ITA 510/IND/2025[2012-13]Status: DisposedITAT Indore23 Dec 2025AY 2012-13

Bench: Ms. Suchitra R. Kambleand**

Section 143(3)Section 250Section 253(5)

passed a meritorious order as per mandate of section 250(6) of the Act which provides *"The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision."*. Therefore, the impugned order

Rajesh Jaiswal, Ramayan vs. Ward 1(4), Indore

Appeal is allowed for statistical purpose

ITA 328/IND/2025[2013-14]Status: DisposedITAT Indore23 Dec 2025AY 2013-14

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniassessment Year:2013-14 Rajesh Jaiswal, Ito Ward 1(4) Ramayan, Scheme No.54, Indore बनाम/ Indore Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Abnpj7642K Assessee By Shri Soumya Bumb, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 23.12.2025

Section 144Section 147Section 253(5)

order passed by CIT(A) is therefore not in accordance with provisions of 250(6) of the Act which provides “The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Gaurang Alloys and Iron Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1257/KOL/2025[2020-21]Status: DisposedITAT Kolkata23 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Accountantmember & Shri Pradip Kumar Choubey, Judicialmember Assessment Year: 2020-21 Dcit, Central Circle-4(3), Kolkata…....………..............................……….……Appellant Vs. Gaurang Alloys & Iron Ltd...………….……………………...……...…..…..Respondent 402A, Mangalam, 24/26, Hemanta Basu Sarani, Kol-1.. [Pan: Aaccg1485A] Appearances By: Dr. Anup Biswas, Cit-Dr,Appeared On Behalf Of The Appellant. Shri S. Jhajharia, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order :December 23, 2025 Order Per Rajesh Kumar: This Is An Appeal Preferred By The Revenue Against The Order Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 25.02.2025Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’)For The Ay 2020-21. 2. The Only Issue Raised By The Revenue In This Appeal Is Against The Order Of Ld. Cit(A) Treating The Undisclosed Cash Sales/Receipts Of Rs.7,54,07,283/- As Business Transaction & Directing The Ao To Apply G.P Rate @ 6.5% To Determine The Profit From The Undisclosed Sales/Receipts.

Section 132(1)Section 139(1)Section 143(1)Section 153ASection 250Section 68

extent of 10.85 lakhs was not found in the books of account. Such amountwas included in the total income of the assessee. The Commissioner (Appeals) gavesubstantial relief to the assessee and reduced the income on the basis of gross profitrate. The Tribunal confirmed the order of the Commissioner (Appeals ... Rameshwar Textile MillsLtd’ ITA 527 & 528 of 2015’, the Hon’ble Gujrat High Court had held the following: 4 Gaurang Alloys and Iron Ltd “Commissioner (Appeals) was of the view that if the entire addition was confirmed, the grossprofit ratio would go upto 23% which was definitely a distorted result

Bharat Solanki, Mumbai vs. DCIT, Central Circle, Mumbai

In the result, all the three appeals of the assessee are allowed

ITA 6525/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Mr. Bharat Kumar
Section 132Section 153CSection 69Section 69C

wherein, on similar facts relating to alleged on-money payments for purchase of shops in the same project, the additions were deleted. The learned Commissioner (Appeals), however, rejected the contentions of the assessee, holding that the right of cross-examination is not absolute, that adequate opportunity had been granted ... natural justice, where such material is sought to be used adversely against an assessee and the assessee specifically disputes its correctness. The learned Commissioner (Appeals) has proceeded on the assumption that since extracts of statements, Excel data, and pen- drive contents were supplied through the show-cause notice, the principles

Bharat Solanki, Mumbai vs. DCIT, Central Circle, Mumbai

In the result, all the three appeals of the assessee are allowed

ITA 6524/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Solgy Jose T. Kottaram, CIT-DR
Section 132Section 153CSection 69Section 69C

wherein, on similar facts relating to alleged on-money payments for purchase of shops in the same project, the additions were deleted. The learned Commissioner (Appeals), however, rejected the contentions of the assessee, holding that the right of cross-examination is not absolute, that adequate opportunity had been granted ... natural justice, where such material is sought to be used adversely against an assessee and the assessee specifically disputes its correctness. The learned Commissioner (Appeals) has proceeded on the assumption that since extracts of statements, Excel data, and pen- drive contents were supplied through the show-cause notice, the principles

Bharat Solanki, Mumbai vs. DCIT, Central Circle, Mumbai

In the result, all the three appeals of the assessee are allowed

ITA 6523/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Bharat KumarFor Respondent: Mr. Solgy Jose T. Kottaram, CIT-DR
Section 132Section 153CSection 69Section 69C

wherein, on similar facts relating to alleged on-money payments for purchase of shops in the same project, the additions were deleted. The learned Commissioner (Appeals), however, rejected the contentions of the assessee, holding that the right of cross-examination is not absolute, that adequate opportunity had been granted ... natural justice, where such material is sought to be used adversely against an assessee and the assessee specifically disputes its correctness. The learned Commissioner (Appeals) has proceeded on the ITA Nos.6523 to 6525/MUM/2025 assumption that since extracts of statements, Excel data, and pen- drive contents were supplied through the show

Mishra Ganesha Ram, Mumbai vs. DCIT, Central Circle 4(2), Mumbai

In the result, appeals of the assessee are allowed

ITA 5556/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

Section 132Section 153CSection 69

assessee was not accededto by the Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th July 2016, had clearly directed the Assessing Officer to provide the assessee all adverse materials / documentary evidences available with him indicating ... with all the adverse material and if, not so, whether he has provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and obvious that the addition of 42 lakh made on account of on-money payment

Mishra Ganesha Ram, Mumbai vs. DCIT, Central Cirlcle, Mumbai

In the result, appeals of the assessee are allowed

ITA 5552/MUM/2025[2020-21]Status: DisposedITAT Mumbai23 Dec 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2019-20 & Assessment Year: 2020-21

For Respondent: Assessee by Shri Bharat Kumar
Section 153C

assessee took up the aforesaid issue Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th July ... provided them to the assessee as per the directions of the learned provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from

Manish Kashiprasad Seksaria, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, appeals of the assessee are allowed

ITA 5501/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20

For Respondent: Assessee by Shri Bharat Kumar
Section 153C

assessee took up the aforesaid issue before Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th ... direct provided them to the assessee as per the direct provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid

Manish Kashiprasad Seksaria, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, appeals of the assessee are allowed

ITA 5500/MUM/2025[2018-19]Status: DisposedITAT Mumbai23 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20

For Respondent: Assessee by Shri Bharat Kumar
Section 153C

assessee took up the aforesaid issue before Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th ... direct provided them to the assessee as per the direct provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid

Manish Kashiprasad Seksaria, Mumbai vs. DCIT Central Circle 4(2), Mumbai

In the result, appeals of the assessee are allowed

ITA 5499/MUM/2025[20187-18]Status: DisposedITAT Mumbai23 Dec 2025

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2017-18 & Assessment Year: 2018-19 & Assessment Year: 2019-20

For Respondent: Assessee by Shri Bharat Kumar
Section 153C

assessee took up the aforesaid issue before Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th ... direct provided them to the assessee as per the direct provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and Commissioner (Appeals). Thus, from the aforesaid

Income Tax Officer-4(3)(1), Mumbai vs. M/S Rajat Diamond Exim Pvt. Ltd, Surat

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1529/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Dec 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation

Income Tax Officier-4(3)(1), Mumbai vs. M/S Rajat Diamond Exim Pvt. Ltd, Surat

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1528/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation

Income Tax Officer-4(3)(1), Mumbai vs. M/S Rajat Diamond Exim Pvt. Ltd, Surat

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1527/MUM/2025[2014-15]Status: DisposedITAT Mumbai23 Dec 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation

Rajat Diamond Exim Private Limited, Mumbai vs. Ward 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1478/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation

Rajat Diamond Exim Private Limited, Mumbai vs. Ward 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1460/MUM/2025[2016-2017]Status: DisposedITAT Mumbai23 Dec 2025AY 2016-2017

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation

Rajat Diamond Exim Private Limited, Mumbai vs. Ward 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1459/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation

Rajat Diamond Exim Private Limited, Mumbai vs. Ward 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee and the Revenue are dismissed

ITA 1458/MUM/2025[2014-15]Status: DisposedITAT Mumbai23 Dec 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 133(6)Section 143(3)Section 144Section 147Section 68

that the assessee could not fully discharge the onus of establishing the identity, creditworthiness, and genuineness of the counterparties. 6. In appeal, the learned Commissioner (Appeals), after an exhaustive examination of the material on record, recorded a categorical finding that the sales corresponding to the alleged bogus purchases were duly ... legally impermissible to treat the same receipts again as unexplained cash credits under section 68 of the Act. At the same time, the learned Commissioner (Appeals) also noted that the assessee had not been able to fully and satisfactorily establish the genuineness of the purchases, thereby justifying an estimation