“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

Tug Indofin Pvt. Ltd., Kolkata vs. DCIT, Circle 8(2), Kolkata

ITA 1914/KOL/2025[2017-2018]Status: DisposedITAT Kolkata15 Jan 2026AY 2017-2018

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 133(6)Section 142(1)Section 143(2)Section 14ASection 250Section 68

were issued by the AO for submission of documents. The AO completed the assessment making addition of Rs.40,00,000 as unexplained cash credit U/s 68 and the Assessing Officer also calculated the disallowance under section 14A read with rule 8D amounting to Rs.34,90,337/-. Tug Indofin

Samudra Commotrade (P) Ltd., Kolkata vs. A.O, NFAC, New Delhi, Delhi

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

ITA 1057/KOL/2023[2009-10]Status: DisposedITAT Kolkata15 Jan 2026AY 2009-10

Bench: Shri George Mathan & Shri Rakesh Mishra

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

income was assessed at ₹9,98,15,720/- by making addition of ₹9,97,50,000/- on account of unexplained cash credit. The assessee filed appeal before the Commissioner of Income tax (Appeals)-5, Kolkata, who vide appeal order dated 04.09.2018 had dismissed the appeal of the assessee. Thereafter

Kameshwar Alloys and Steels Pvt. Ltd., Kolkata vs. ACIT, Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 49/RAN/2024[2014-15]Status: DisposedITAT Ranchi14 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

Section 131Section 132(1)Section 133(6)Section 133ASection 143(3)Section 144Section 153ASection 250Section 68

despite furnishing extensive documentary evidence by the assessee made an addition of ₹2,00,00,000 under section 68 of the Act as unexplained cash credit and also disallowed ₹14,182 towards penal expenses. 3. Aggrieved the order of the Assessing Officer, the assessee preferred an appeal before

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Nice Exports Private Limited, A-15A, Phase-VII, Focal Point, Ludhiana

In the result, all the above appeals filed by the Revenue are dismissed

ITA 730/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh14 Jan 2026AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Nitin Mahajan, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 68

made an addition of Rs . 4,43,96,119/- under section 68 of the Income-tax Act, 1961, treating certain foreign remittances as unexplained cash credits. The addition arose from receipt of 11 wire transfers aggregating to USD 7,98,872 from a Canadian entity, namely M/s Goel Foreign Exchange ... sales were accepted and the corresponding income was brought to tax as business income, the same receipts could not again be treated as unexplained cash credits under section 68, as such an approach would result in impermissible double taxation. It was submitted that section 68 cannot be invoked in isolation

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Nice Exports Private Limited, A-15A, Phase-VII, Focal Point, Ludhiana

In the result, all the above appeals filed by the Revenue are dismissed

ITA 729/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh14 Jan 2026AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Nitin Mahajan, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 68

Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Nice Exports Private Limited, A-15 A Phase, Focal Point, Ludhiana

In the result, all the above appeals filed by the Revenue are dismissed

ITA 728/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh14 Jan 2026AY 2013-14

Bench: or at the time of hearing of appeal.

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Nitin Mahajan, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 68

Income Tax Officer, Ludhiana vs. Kapil Kumar & Sons(HUF), Ludhiana

In the result, Cross Objections is dismissed

ITA 1086/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh14 Jan 2026AY 2011-12

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1086/Chd/2025 "नधा"रण वष" / Assessment Year: 2011-12 The Ito, Kapil Kumar & Sons (Huf), Ludhiana. Vs 27-A, Rakh Bagh, Mall Road, Ludhiana. "थायी लेखा सं./Pan No: Aaahk6588H अपीलाथ"/Appellant ""यथ"/Respondent & C.O. 1/Chd/2026 In आयकर अपील सं./ Ita No. 1086/Chd/2025 "नधा"रण वष" / Assessment Year: 2011-12 Kapil Kumar & Sons (Huf), The Ito, 27-A, Rakh Bagh, Mall Road, V Ludhiana. Ludhiana. S "थायी लेखा सं./Pan No: Aaahk6588H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.As Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr Date Of Hearing : 12.01.2026 Date Of Pronouncement : 14.01.2026

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, C.AsFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr.DR

Section 10(38)Section 148

Appellant has made the sale and purchase of shares through banking channel, therefore the stand of AO treating the sale receipts as unexplained cash credits under the provisions of section despite of explaining the source of credits, is not justified. The Addition of Rs. 5,60,611/- under the provisions

Kishor Vitthal Kolhe, Jalgaon vs. DCIT-Circle-1, Jalgaon

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

ITA 1876/PUN/2025[2017-18]Status: DisposedITAT Pune14 Jan 2026AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Vinay Kawadia (through virtual)For Respondent: Shri Vidya Ratna Kishore

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

made by the Assessing Officer u/s 68 of the Act by treating the sale proceeds credited to the Profit and Loss Account as unexplained cash credit cannot be sustained: i) PCIT vs. Tripati Proteins (P.) Ltd. (2024) 165 taxmann.com 175 (Guj) ii) CIT vs. Vishal Exports Overseas Ltd. (Tax Appeal ... total cash deposit of Rs.2,60,27,680/- during the demonetization period treating the same as unexplained cash credit. We find the Ld. CIT(A) / NFAC substantially sustained the addition made by the Assessing Officer, the reasons of which have already been reproduced in the preceding 10 paragraphs

ACIT, Chennai vs. M/S. Bsr Builders Engineers Contractors, Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1561/CHNY/2025[2016]Status: DisposedITAT Chennai14 Jan 2026

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

unable to substantiate the low rent received or the genuineness of the deposit and therefore added the outstanding liability by way of unexplained cash credit u/s 68 of the Act. On appeal, the Ld. CIT(A) was pleased to confirm the action of the AO. Aggrieved, the assessee

Bsr Builders Engineers Contractors, Chennai vs. DCIT, Central Circle-2(3), Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1312/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Jan 2026AY 2017-18

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

Bsr Builders Engineers Contractors, Chennai vs. DCIT, Cent. Circle-2(3), Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1311/CHNY/2025[2016-17]Status: DisposedITAT Chennai14 Jan 2026AY 2016-17

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

DCIT, Chennai vs. Bsr Builders Engineers Contractors, Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1274/CHNY/2025[2017]Status: DisposedITAT Chennai14 Jan 2026

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

Sonal Jain, Delhi vs. Commissioner of Income Tax (Appeal), Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 7162/DEL/2025[2016-17]Status: DisposedITAT Delhi14 Jan 2026AY 2016-17

Bench: Shri Vikas Awasthyआअसं.7162/धिल्ली/2025 (नि.व. 2016-17) Sonal Jain, 50, Madhuban, Delhi 110092 ...... अपीलार्थी/Appellant Pan: Ackpj-0124-G बिाम Vs. Commissioner Of Income Tax (Appeals), ..... प्रनिवादी/Respondent Delhi अपीलार्थी द्वारा/Appellant By : S/Shri Prasoon Agarwal & Rahul Bansal, Chartered Accountants प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 14/01/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), Delhi-43 [In Short ‘The Cit(A)’] Dated 09.09.2025, For Assessment Year 2016-17. 2. The Facts Of The Case In Brief Are: The Assessee Was Employed In The Uk, Hence, Was A Non-Resident During The Relevant Period. Assessment Proceedings U/S 147 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) Were Initiated On Receipt Of Information That The Assessee Had Purchased Immovable Property For A Consideration Of Rs. 37,39,427. Notice U/S.148 Of The Act Was Issued. In Response To Said Notice The Assessee Filed Return Of Income Declaring Income Of Rs.1,07,249/- . During Assessment Proceedings, The Assessing Officer (Ao) Noted That There Were 2 Cash Deposits Totaling To Rs. 1,97,800 In Assessee’S Icici Bank Account During Ay 2016-17. The Assessee Explained Source Of Cash Deposits As Rental Income & Shaguns & Gifts Received From Family Members. In Absence Of Documentary Evidence To Support Assessee'S Claim, The Ao Treated The Said Amount As Unexplained Cash Credit U/S 68 Of The Act & Made Addition Of The Same. In Appeal Before The Cit(A), The Assessee Remained Unsuccessful.

For Appellant: S/Shri Prasoon Agarwal & Rahul BansalFor Respondent: Shri Manoj Kumar, Sr. DR

Section 147Section 148Section 68

gifts received from family members. In absence of documentary evidence to support assessee's claim, the AO treated the said amount as unexplained cash credit u/s 68 of the Act and made addition of the same. In appeal before the CIT(A), the assessee remained unsuccessful. 3. Shri Prasoon Agarwal

Bg Steel Private Limited, Bhiwadi vs. Income Tax Officer, Delhi

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

ITA 6255/DEL/2025[2012-13]Status: DisposedITAT Delhi14 Jan 2026AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Vishu Arora, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 133(6)Section 143(1)Section 148Section 234BSection 250Section 6Section 68

erred both on facts and in law in making the addition of Rs.2,68,11,923/- treating the Share Application Money as unexplained cash credit invoking the provisions of Section 68 of the Act. That the addition has been made misinterpreting the submission of the assessee. That the addition ... company. He, therefore, rejected the confirmations as non genuine and treated the entire sum of Rs. 2,68,11,963/- as unexplained cash credit u/s 68 of the Act. 3 | P a g e M/s B G Steels Pvt Ltd. Accordingly, assessment was completed at an income

Puneet Kohli, Delhi vs. The Assessment Unit, Delhi

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

ITA 6228/DEL/2025[2020-21]Status: DisposedITAT Delhi14 Jan 2026AY 2020-21

Bench: Shri Mahavir Singh, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Ms. Shruti Gupta, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 148Section 250Section 68Section 69Section 69A

facts and in circumstances of case and in law, in making and addition of Rs. 70,94,025/-by the disallowance of unexplained cash credits u/s 68 being unexplained Current liabilities and provisions/current liabilities/sundry creditors to the assessment unit. Ground No. 6 That on the facts and in circumstances ... Assessment was completed at an income of Rs. 3,64,18,689/- after making further disallowance of expenses and addition on account of unexplained cash credits etc. Aggrieved, the assessee preferred an appeal before Ld. CIT(A). However, Ld. CIT(A) dismissed the assessee’s appeal on the ground that

Hector Enterprises Pvt. Ltd, Delhi vs. DCIT, Central Circle- 29, Delhi

ITA 1692/DEL/2024[2019-20]Status: DisposedITAT Delhi14 Jan 2026AY 2019-20

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 115JSection 132Section 132(4)Section 143Section 143(3)Section 153ASection 45

1 ITA Nos. 1692/Del/2024 Hector Enterprises Pvt. Ltd. vs. DCIT IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘B

Nishan Inbuild Limited, Delhi vs. Pr, CIT Central Knp, Meerut

Appeal is allowed

ITA 2033/DEL/2023[2013-14]Status: DisposedITAT Delhi14 Jan 2026AY 2013-14

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

Section 153ASection 153CSection 263Section 68

triggering initiation of section 153C proceedings. All this finally culminated in the impugned assessment wherein the Assessing Officer added the corresponding section 68 unexplained cash credits and commission income @ 4% in the assessee’s hands on “protective” basis as a matter of abundant caution. 4. Learned CIT(DR) at this

The DCIT, 1(1), Indore vs. M/S. Ritspin Synthetics Ltd., Pithampur

In the result, the appeal filed by the Department is allowed for statistical purposes, in terms indicated above, and the cross-objections filed by the assessee are dismissed as not pressed

ITA 213/IND/2023[2017-18]Status: DisposedITAT Indore13 Jan 2026AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Shri S. N. Agarwal, C.A. and Shri Pankaj Mogra, C.AFor Respondent: Shri Anup Singh, CIT DR

Section 11Section 115BSection 143(2)Section 68

unsecured loans were not established. Accordingly, the Assessing Officer added the entire amount of unsecured loans of ₹4,10,00,000/- as unexplained cash credit under section 68 of the Act and taxed the same under section 115BBE of the Act. Consequentially, the interest expenditure of ₹25,27,261/- paid

Shaurya Developers, Ahmedabad vs. DCIT, Cent Cir 2(1) Ahmedabad, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1934/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad13 Jan 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kambleshaurya Developers, Vs. 314, 2 N D Floor, New Cloth Market, Dcit, Raipur, Kankaria, Ahmedabad Central Circle 2(1), Ahmedabad [Pan : Abtfs 7179 J]

Section 143(2)Section 250Section 68

from M/s. Olympic Corporation and Rs. 1,00,000/- on account of amount received from M/s. Ritesh Patel & Sons, treating the same as unexplained cash credits u/s 68 of the Act. Notice under section 143(2) of the Act was issued on 10.08.2018. The assessee had filed its return

Satish Nagesh Kulkarni, Secunderabad vs. DCIT., Circle-10(1), Hyderabad

ITA 1025/HYD/2025[2016-17]Status: DisposedITAT Hyderabad13 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1025/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satish Nagesh Kulkarni, Vs. Dcit, Secunderabad. Circle-10(1), Pan: Begpk9791B Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: None राज" व "ारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 13/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/01/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal Before Us:

For Appellant: NoneFor Respondent: Shri K. Vinoth Kannan, Sr

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

sources of cash deposits, the peak debit of Rs.1,33,03,402/- is added to the Total Income of the assessee as unexplained cash credits u/s.68 of the Act.” 14. We have given thoughtful consideration, and though, principally concur with the AO that the assessee had failed to substantiate