“unexplained cash credit”

Cash Credits & Unexplained ItemsSection 68Section 687,118 judgments

The decision most relied on for unexplained cash credit is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on unexplained cash credit

Sumati Dayal v. CIT

214 ITR 801 · 1995 · Supreme Court

1,967

citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Orissa Corporation Pvt. Ltd.

159 ITR 78 · 1986 · Supreme Court

897

citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

(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.

CIT v. P. Mohanakala

291 ITR 278 · 2007 · Supreme Court

525

citing judgments

The Supreme Court emphasized that in the absence of concrete rebuttal by the assessee, circumstantial evidence holds significant weight, applying the doctrine of preponderance of probability, particularly when assessing undisclosed income or unexplained cash credits.

Judgments citing unexplained cash credit

ITO Exmp, Agra vs. Hardayal Charitable & Educational Trust, Firozabad

In the result, both the revenue appeals ITA No

ITA 245/AGR/2017[2012-13]Status: DisposedITAT Agra16 Feb 2026AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 11Section 12ASection 143Section 250Section 56Section 68

Revenue has further argued that the said exemption cannot be allowed as the said unsecured loans were held as bogus /fictitious and unexplained cash credits. It transpires from the perusal of the impugned order, that the first appellate authority has not specifically dealt with the issue of bogus purchases

Durgawati Panday, Baikunthpur vs. Income Tax Officer Ward No 01, Ambikapur

In the result, appeal of the assessee is allowed

ITA 14/RPR/2026[2020-21]Status: DisposedITAT Raipur16 Feb 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.14/Rpr/2026 "नधा"रण वष" /Assessment Year : 2020-21 Durgawati Panday Ward No.9, Mahalpara, Baikunthpur, Koriya Chhattisgarh-497 335 Pan: Dsipp8404G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward 1, Ambikapur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Prashant Gupta, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 144BSection 147Section 3Section 68Section 69A

loan transaction and if at all, additions were to be made, it should have been done u/s.68 of the Act i.e. unexplained cash credit in the hands of the assessee. The Revenue should have examined the applicability of Section 68 of the Act to the facts of the assessee

Saket Products and Rolling Mill Pvt. Ltd., Surguja vs. Income Tax Officer, Ward-1, Ambikapur

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

ITA 840/RPR/2025[2018-19]Status: DisposedITAT Raipur16 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 840/Rpr/2025 (िनधा"रण वष" Assessment Year: 2018-19) Saket Products & Rolling Mill Vs Income Tax Officer, Ward 1, Private Limited, Aykar Bhawan, Kharsia Road, Subhash Marg, Bhaiyathan Road, Ambikapur, C. G., 497001 Surajpur, Surguja (C.G.) 497229 Pan: Aajcs2709N (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri G. S. Agrawal, Ca राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/02/2026 घोषणा की तारीख / Date Of : 16/02/2026 Pronouncement

For Appellant: Shri G. S. Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 148Section 148ASection 250

amounting to Rs.38,00,000/- done by the assessee company with Mis Palak Enterprise is remains unexplained and the same is treated as unexplained cash credit as per provisions of section 68 and to be taxed u/s 1158BE of act. Penalty Proceedings under Sec.274 read with Section 271AAC

Jadav Jewellers Pvt. Ltd., Chennai vs. ITO, Corporate Ward-2(3), Chennai

The appeal of the assessee is allowed

ITA 2911/CHNY/2025[2013-14]Status: DisposedITAT Chennai16 Feb 2026AY 2013-14

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2911/Chny/2025 िनधा"रण वष" /Assessment Year: 2013-14

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. R. Anitha, Addl. CIT

Section 143(3)Section 144BSection 147Section 148Section 154Section 250Section 68

Learned CIT(A) erred in confirming the addition of Rs. 1,48,00,000/- under Section 68 of the Act as unexplained cash credit, without appreciating that no such sum was received by the Appellant during the year under consideration and that the alleged amounts did not appear as credits ... Officer's findings were based merely on conjectures and surmises, without any supporting material or enquiry to establish that the Appellant received any unexplained cash credits during the relevant AY. For these and such other grounds as may be urged at the time of hearing, the Appellant prays that

Mayur Praful Baxi, Mumbai vs. Asst. Commissioner of Income Tax 22(1), Mumbai

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 6818/MUM/2025[2010-11]Status: DisposedITAT Mumbai16 Feb 2026AY 2010-11

Bench: Shri Anikesh Banerjee & Shri Girish Agrawalassessment Year: 2010-11

For Appellant: NoneFor Respondent: Shri Sushil R. Shendge, Sr. DR

Section 143(3)Section 68

assessee are reproduced as under: “1. The learned Commissioner of Income Tax Appeal, has erred in confirming addition out of loans as unexplained Cash credits under section 68 of the Income Tax Act, 1961 of 12,20,814/ In view of the above additions made by learned officer be deleted

Jaishri Shivaji Waghralkar, Mumbai vs. ITO-Ward 22(1)(6), Mumabi

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

ITA 6781/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Feb 2026AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Girish Agrawalassessment Year: 2016-17 Jaishri Shivaji Waghralkar Income Tax Officer – Ward 22(1) 102A, Dadasaheb Phalke (6), Mumbai Marg, Navin Asha Chs, Vs. Dada (East), Mumbai 400014 (Pan: Aaupw9953G) (Appellant) (Respondent) Present For: Assessee : Shri Ketan Vajani, Ca Revenue : Shri Sushil B. Shendge, Sr. Dr Date Of Hearing : 10.02.2026 Date Of Pronouncement : 16.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2025-26/1080005281(1), Dated 26.08.2025, Passed Against The Assessment Order By Income Tax Officer, Ward 21(1)(5), Mumbai, U/S. 143(3) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 27.12.2018 For Assessment Year 2016-17. 2. Grounds Taken By Assessee Are Reproduced As Under: 1. On The Facts & In The Circumstances Of The Case, The Commissioner Of Income- Tax (Appeals) - Nfac, Hereinafter Referred To As The "Cit (A)", Has Erred In Dismissing The Appeal Of The Appellant Ex-Parte. The Appellant Respectfully Submits That The Notice Dated 10-7-2025 Remained Non-Complied Only On Account Of Non-Communication Of The Same To The Appellant. The Appellant Submits That The Cit(A) Has Erred In Passing The Appeal Order Without Any Further Notice To The Appellant.

For Appellant: Shri Ketan Vajani, CAFor Respondent: Shri Sushil B. Shendge, Sr. DR

Section 143(3)Section 68Section 69

provisions of section 69. Addition of Rs.10,40,000/- was also made towards deposit of cash in her bank account treating it as unexplained cash credit u/s. 68. In the first appeal before ld. CIT(A), assessee could not furnish any details and explanations though ample opportunities were given

M/S. Armstrong Energy Pvt Ltd, Mumbai vs. The DCIT 6(1)(1), Mumbai

ITA 3395/MUM/2025[2008-09]Status: DisposedITAT Mumbai16 Feb 2026AY 2008-09

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarm/S Armstrong Energy Pvt. Vs. Dcit 6(1) (1), Mumbai Ltd. Room No. 504, 5Th 5Th Floor, Militia Apartment, Floor, Aayakar Bhavan, Mathur Pakhadi Road, M.K. Road, Mazgaon, Mumbai 400020 Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Acit 6(1) (1), Mumbai Vs. M/S Armstrong Energy Pvt. Room No. 504, 5Th Floor, Ltd. Aayakar Bhavan, M.K. 5Th Floor, Militia Road, Apartment, Mathur Mumbai 400020 Pakhadi Road, Mazgaon, Mumbai - 400010 Pan/Gir No. Aafca3807R (Applicant) (Respondent) Assessee By Shri Nishit Gandhi Revenue By Shri Rajesh Kumar Yadav (Cit-Dr) Date Of Hearing 10.12.2025 Date Of Pronouncement 16.02.2026 आदेश / Order Per Sandeep Gosain, Jm: M/S. Armstrong Energy Pvt. Ltd.

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151(2)Section 251(1)(a)Section 68

then came to the conclusion that the same were unexplained in nature and is a non- genuine transaction and treated the same as unexplained cash credit.” 2. Ground No. 1 raised by the Assessee and Ground Nos. 1 to 3 raised by the Revenue are inter-related and interconnected

Raj Sharadkumar Agarwal, Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 3290/MUM/2025[2014-15]Status: DisposedITAT Mumbai16 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Priyanka Jain, Shri Pankaj Soni & Shri Rohan MittalFor Respondent: Shri Umashankar Prasad (CIT DR)

Section 10(38)Section 131Section 133(6)Section 143(3)Section 250

were claimed as exempt under section 10(38). However, the assessing officer disallowed the exemption and added the amount of capital gains as unexplained cash credit transactions were duly reflected in the bank account and D-mat account of the assessee and the holding of assessing officer was merely ... under section 12 Raj Sharadkumar Agarwal 10(38). However, the assessing officer disallowed the exemption and added the amount of capital gains as unexplained cash credit under section 68 treating the transactions in shares as bogus. The Tribunal followed the order of coordinate bench in the case of Megharaj SinghShekhawat

ACIT-6(1)(1), Mumbai vs. Armstrong Energy Pvt. Ltd., Mumbai

ITA 2940/MUM/2025[2008-09]Status: DisposedITAT Mumbai16 Feb 2026AY 2008-09

Section 143(1)Section 143(3)Section 144Section 147Section 148Section 151(2)Section 251(1)(a)Section 68

Venkatanarayana Peetha, Guntur vs. Income Tax Officer, Ward-1, Tenali

In the result, the appeal of the assessee is partly allowed

ITA 731/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam13 Feb 2026AY 2017-18

Bench: the AO, an addition of Rs.12.51 lakhs was made u/s 69A of the Act. While concluding the assessment, the Ld.AO has mentioned that the assessee opened an account in the Corporation Bank, Brundavan Gardens, Guntur only during demonetisation period, which clearly exhibits and deemed that the assessee has accommodated others money to deposit in his bank account in the guise of sources emanated out of agricultural savings of him. It was also mentioned that the vague explanation given with regard

Section 153CSection 69A

proof, makes the claim as not genuine. Since the assessee failed to explain the source of cash deposits, the same was treated as unexplained cash credit and section 69A was invoked to tax the same. 3. As the AO made addition u/s 69A, an appeal was filed before the Ld.CIT

Sarfarazkhan Sarvarkhan Pathan, Ahmedabad vs. ITO, Ward3(3)(5), Ahmedabad

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

ITA 2016/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P D Shah, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68Section 69Section 69A

/National Faceless Appeal Centre, Delhi has erred in law and facts by confirming the addition amount of Rs.6,00,000/- and treated as unexplained cash credit u/s 68 of the Act, and therefore the learned AO should be directed to delete the impugned addition while computing the total income ... Assessing Officer made additions of Rs.47,48,500/- as unexplained cash deposits under section 69A of the Act, Rs.6,00,000/- as unexplained cash credit under section 68 of the Act, Rs.1,35,82,765/- as unexplained investment under section 69 of the Act in respect of transactions with Bhargava

Income Tax Officer, Ward-1, Anand vs. Chikhodara Sewa Sahkari Mandali Ltd, Anand

In the result, the appeal of the revenue is dismissed

ITA 1571/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalthe Income Tax Officer, Chikhodara Sewa Sahakari Vs. Ward-1, Mandali Ltd., Anand. Nr. Patel Wadi, Opp. Swaminarayan Temple, Chikhodra, Anand-388320. [Pan :Aaaac0897 L] (Appellant) .. (Respondent) Appellant By : Shri Kamal Deep Singh, Sr. Dr Respondent By: Shri S.N Divatia, With Shri Samir Vora, Ars Date Of Hearing 08.12.2025 Date Of Pronouncement 13.02.2026

For Appellant: Shri Kamal Deep Singh, Sr. DRFor Respondent: Shri S.N Divatia, with Shri Samir Vora, ARs

Section 250Section 68

Assessing Officer, acceptance of demonetized currency was illegal and the said amount represented unexplained money. The Assessing Officer, therefore, treated the amount as unexplained cash credit and made an addition of Rs. 93,75,500/- to the total income of the assessee. 4. Aggrieved by the assessment order, the assessee

M/S. Bodal Chemicals Limited, Ahmedabad vs. The Dy.CIT., Central Circle-1(1), Ahmedabad

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

ITA 104/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Alpesh Parmar, CIT (DR)

Section 250Section 35(1)(ii)Section 80Section 801ASection 80A(5)Section 80I

wholly misconceived as no credit entry exists in the books of account and the issue relates to disallowance of expenditure and not unexplained cash credit. Reliance is placed on the decision of the Delhi ITAT in Feather Infotech (P.) Ltd. (161 taxmann.com 441), wherein it has been held that sections

Vikas Vaishnav HUF, Mumbai vs. ITO Ward 19(3)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 8125/MUM/2025[2023-24]Status: DisposedITAT Mumbai13 Feb 2026AY 2023-24

Bench: Shri Anikesh Banerjee & Shri Girish Agrawalvikas Vaishnav Huf Vs Ito Ward 19(3)(1), Mumbai Office No. Lg 81 G, Lower Room No.405, 4Th Floor, Piramal Ground Floor, Express Zone Chamber, Lal Baugh, Parel, Mall, A Wingh, Western Mumbai-400012 Express Highway, Opp Adani Electricity, Malad (East) Mumbai-400097 Pan: Aalhv5953J Appellant Respondent Assessee By : Shri Himanshu Gandhi, Respondent By : Shri Sushil Shende (Sr Dr) Date Of Hearing : 09/02/2026 Date Of Pronouncement : 13/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Nfac, Delhi [For Brevity ‘The Ld. Cit(A)’], Order Passed Under Section 250 Of The Income Tax Act, 1961 (For Brevity ‘The Act’) For Assessment Year 2023-24, Date Of Order 12.09.2025. The Impugned Order Emanated From The Order Of The Assessment

For Appellant: Shri Himanshu GandhiFor Respondent: Shri Sushil Shende (SR DR)

Section 139(1)Section 143(3)Section 250Section 68Section 69C

credit purchases added during the year of Rs. 110,47,06,734/- in respect of Feriha Exm Pvt Ltd, is treated as unexplained cash credit u/s 68 of the Act. Being aggrieved the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A) uphold theimpugned assessment order

Rasila Lalitkumar Cholera, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 7544/MUM/2025[2011-12]Status: DisposedITAT Mumbai13 Feb 2026AY 2011-12

Bench: Smt. Beena Pillai ()

Section 143(1)Section 147Section 148Section 68Section 69Section 69C

Without prejudice to above, the CITA has erred is confirming the taxing of total gross sales proceeds as Unexplained Cash Credit U/s.68 of the Act even though records of Broker and Bank are in place. 8. CITA has erred in confirming the action o the learned AO in adding Unexplained

Chetan Shashikant Thakkar, Mumbai vs. DCIT, Circle 27(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7320/MUM/2025[2015-16]Status: DisposedITAT Mumbai13 Feb 2026AY 2015-16

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Vishal D. Shah, CAFor Respondent: Shri Virabhadra Mahajan, (Sr. DR)

Section 133Section 143(3)Section 147Section 148Section 250Section 69

circumstances of the case, the Ld. CIT(A) erred in confirming the addition of Rs. 1,00,00,000/- u/s 69 as unexplained cash credit, ignoring that the said sum represented a personal loan received by the Appellant from his friend Mr. Mitu Misra (PAN: APIPM1203L), the identity and creditworthiness

Dilip Bhanwerlal Dangi (HUF), Palghar vs. Income Tax Officer, WD-26(1)(3), Mumbai

In the result, appeal of the assessee stands allowed

ITA 6008/MUM/2025[2014-15]Status: DisposedITAT Mumbai13 Feb 2026AY 2014-15

Bench: Smt. Beena Pillai ()

Section 10(38)Section 142(1)Section 143(2)Section 68

After examination, the Ld. AO rejected the exemption claimed u/s 10(38) and treated the entire sale consideration of ₹19,97,200/- as unexplained cash credit u/s 68 of the Act, alleging that the transaction of sale and purchase was not genuine and formed part of accommodation entry scheme. Aggrieved

Santush Pandurang Mane, Mumbai vs. DCIT Circle 8(3)(1), Mumbai

ITA 4528/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Feb 2026AY 2016-17

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Fenil BhatFor Respondent: Shri Virabhadra Mahajan, Sr. DR

Section 142(1)Section 143(2)Section 250Section 68Section 80C

case and in law the Learned CIT(A) erred in upholding the addition made by the Assessing Officer, of Rs.78,70,208/- as unexplained cash credit u/s 68 of the Income Tax Act, 1961. b) On the facts and in the circumstances of the case and in law the Learned ... amounting to Rs.78,70,208 declared by the assessee and credited in the books of account. Accordingly, the said amount was treated as unexplained cash credit under section 68 of the Act and added to the total income of the assessee. 6. The learned CIT(A), vide impugned order, dismissed

JCIT(OSD)-14(1)(1), Mumbai vs. Kukreja Builders Pvt. Ltd., Mumbai

In the result, the revenue’s appeal is partly allowed in the above terms

ITA 2102/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Feb 2026AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2013-14 Dcit – 14(1)(1), Mumbai M/S. Kukreja Builders Room No. 432, 4Th Floor, Pvt. Ltd. Aayakarbhavan, M.K. Road, 4 & 5Th Floor, Sai Mumbai - 400020 Commercial Building, Bks Vs. Devshi Marg., Govandi (E), Mumbai, Maharashtra– 400088 Pan: Aacck5040M (Appellant) (Respondent) Present For: Assessee By : Shri Ajay Singh & Shri Akshay Pawar, Ld. A.R. Revenue By : Shri Hemanshu Joshi, (Sr. D.R.) Date Of Hearing : 12.12.2025 Date Of Pronouncement : 13.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2013-14. 2. In The Instant Case, The Assessee During The A.Y. Under Consideration Had Declared Its Total Income As Rs. 2,20,00,580/- By Filing Its Return Of Income, Which Was Initially Processed Under Section 143 Of The Act. 2 M/S. Kukreja Builders Pvt. Ltd.

For Appellant: Shri Ajay Singh & Shri AkshayFor Respondent: Shri Hemanshu Joshi, (SR. D.R.)

Section 131Section 133(6)Section 143Section 250Section 68

been satisfactorily explained by the Assessee company. 16. Thus, the Assessing Officer, ultimately, made the addition of Rs. 3,80,00,000/- as unexplained cash credit, within the meaning of Section 68 of the Act and added the same to the total income of the Assessee. 17. The Assessing Officer ... prove the creditworthiness of the mentioned parties will be served and there would not be any reason left to make the addition of unexplained cash credit u/s. 68 of the IT Act, 1961.” 20. The Ld. Commissioner by considering the grounds of appeal, statement of facts, Assessment Order

M/S Fairdeal Information Technology Private Limited, New Delhi vs. Income Tax Officer, Ward 9(1), Delhi

In the result all the three grounds of appeal of the assessee are allowed

ITA 2793/DEL/2025[2013-14]Status: DisposedITAT Delhi13 Feb 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalm/S Fairdeal Information Income Tax Officer, Technology Private Limited, Ward-9(1), 116A, First Floor, Somdutt Vs. New Delhi. Chamber-1, 5, Bhikaji Cama Place, New Delhi-110066. Pan-Aaacf9581G (Appellant) (Respondent) Assessee By Shri Ashwani Kumar, Ca & Shri Ankur Agarwal, Ca Department By Ms. Indu Bala Saini, Sr. Dr Date Of Hearing 20/01/2026 Date Of Pronouncement 13/02/2026

Section 147Section 148Section 148ASection 250Section 68

Rs.12,00,00,000/- being amount received as consideration from the sale of shares owned by assessee by holding the same as unexplained cash credit. 4. Aggrieved by the said order, assessee filed the present appeal before the Tribunal by taking following grounds of appeal: 1. “That the order dated ... declared and due taxes were paid. Once the said transactions of sale of shares were disclosed, treating the sale consideration as unexplained cash credit by wrongly treating the ale consideration as receipts against issue of share capital clearly shows the arbitrary approach of the lower authorities who made / uphold