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“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

Income Tax Officer, Ward 2(1), Raipur vs. Mesers Aryan Builders and Developers Private Limited, Raipur

In the result, both appeal of the revenue and cross objection of the assessee stand dismissed in terms of our observations

ITA 201/RPR/2018[2012-13]Status: DisposedITAT Raipur06 Sept 2023AY 2012-13

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Appellant: Shri Ramesh Kumar Singhania, CA, &For Respondent: Shri S.K.Meena, CIT-DR
Section 143(2)Section 250(4)Section 68

genuineness of the impugned transactions. It is observed from the records and assessment order that for the purpose of making addition as unexplained cash credits, the AO has heavily relied upon the judicial pronouncements, however, the appellant has made elaborate submissions distinguishing the facts, I am convinced with the explanation ... share application/capital money of Rs. 12,71,00,000/- in A.Y 2006-07 and Rs.6,51,50,000/- in A.Y 2007-08 as unexplained cash credits under section 68 are uncalled for and hence, deleted." 7.5. Honorable Supreme Court in the case of Lovely Exports

DCIT-15(3)(1), Mumbai vs. M/S. Translands Infrastructure Developers P Ltd, Vashi

In the result, the appeal of the revenue is dismissed

ITA 1913/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 Sept 2023AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailthe Dy. Commissioner Of Vs. M/S Translands Income-Tax, 15(3)(1), Infrastructure Developers Mumbai P. Ltd. Jn-3-14-5, Asshirwad Chs, Sector-09, Vashi, Navi Mumbai-400 703 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadct 0036 B Appellant .. Respondent

For Appellant: Ms. Rupa NandaFor Respondent: Shri P. D. Chougule, Sr. AR
Section 143(3)Section 147Section 269SSection 271DSection 273BSection 3Section 68

271D for failure to comply with the provisions of section 269SS of the act was initiated in respect of addition on account of unexplained cash credit u/s 68 of the Act of Rs. 1,85,00,000/- being opening balance payable to M/s Sampada Chemicals Ltd as on 1st April ... 11th Dec, 2007 and penalty u/s 271D was initiated for violation to comply with the provisions of section 269SS on account of unexplained cash credit added u/s 68 of the Act on account of payment of Rs. 1,85,00,000/- made to M/s Sampada Chemicals Ltd on behalf

Jyoti Sharma, Bhilai, Durg vs. Income Tax Officer, Ward1(2), Bhilai, Durg

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of my observations mentioned above

ITA 254/RPR/2023[2015-16]Status: DisposedITAT Raipur05 Sept 2023AY 2015-16

Bench: Shri Ravish Soodआयकर अपील सं. / Ita No. 254/Rpr/2023 "नधा"रण वष" / Assessment Year : 2015-16 Jyoti Sharma Qr No.3D, St 30, Sector-1, Bhilai, Durg-490 001 Pan : Avtps5669P .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(2)Section 143(3)Section 56Section 68

Appeals-NFAC and AO have erred in facts and in law in treating the entire agricultural receipts of Rs.20,52,410/- as unexplained cash credits without considering that only Rs.5,00,000/- has been deposited in Bank. 3. That CIT Appeals-NFAC while confirming the addition made ... assessee had failed to prove her claim of having garnered agriculture income of Rs.20,52,410/-, therefore, the A.O dubbed the same as unexplained cash credit u/s.68 of the Act. 4. Further, it was observed by the A.O that the assessee had made cash deposits of Rs.5

Mr Bimal H. Kiri, Mumbai vs. Assistant Commissioner of Income Tax. Circle 19(1), Mumbai

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

ITA 1335/MUM/2023[2011-2012]Status: DisposedITAT Mumbai04 Sept 2023AY 2011-2012
For Appellant: Shri Neelkanth Khandelwal &For Respondent: Ms. R.M Brindha.DR
Section 143(2)Section 143(3)

Income Tax Officer ward 16(3)(4) Mumbai has erred in law to add a sum of Rs. 49,504/- a unexplained cash credit. 3. On the facts and in the circumstances of the case, the Ld. Income Tax Officer Ward 16(3)(4) Mumbai has erred ... summery of cash book furnished by the assessee, there is a difference of Rs.49,504/- and made addition as unexplained cash credit U/sec 68 of the Act. The third disputed issue, the AO found that the assessee has claimed Rs1,86,423/- in the profit & Loss account in respect

Chandrahasni Ispat Pvt Ltd, Raigarh vs. Assistant Commissioner of Income Tax, Circle-1(1), Bilaspur

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of our observations mentioned above

ITA 177/RPR/2022[2017-18]Status: DisposedITAT Raipur04 Sept 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.177/Rpr/2022 "नधा"रण वष" / Assessment Year : 2017-18 Chandrahasni Ispat Private Limited Gerwani, Saraipalli Road, Raigarh-496 001 Pan : Aaccc9257G .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(2)Section 143(3)Section 251(1)(a)Section 251(2)Section 68

assessment vide his order passed u/s.143(3) dated 14.12.2019, wherein after treating the share application money of Rs.1,64,49,966/- as an unexplained cash credit u/s. 68 of the Act, the income of the assessee company was assessed at Rs.2,40,17,420/-. 5. Aggrieved the assessee carried

The Omkar Urban Co-Operative Credit Society Limited, Belagavi vs. Income Tax Officer, Ward - 1, Belagavi

The appeal is ALLOWED FOR STATISTICAL PURPOSE in aforestated terms

ITA 84/PAN/2022[2017-18]Status: DisposedITAT Panaji01 Sept 2023AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshali(Through Virtual Hearing From Pune) आयकर अपऩल सं. / Ita No. 84/Pan/2022 निर्धारण वषा / Assessment Year : 2017-18 The Omkar Urban Co-Op. Cr. Society Ltd. A/P. : Kangral (Bk.), Belagavi. Pan: Aaaat3508P . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Chetan Chougule [‘Ld. AR’]For Respondent: Mr N. Shrikanth [‘Ld. DR’]
Section 139(1)Section 142(1)Section 144Section 144(1)(b)Section 250Section 253(1)Section 68Section 80ASection 80P(2)Section 80P(2)(a)

return of income filed beyond prescribed due date in response to notice u/s 142(1) of the Act. (2) addition towards unexplained cash credit owning to failure to substantiate the cash deposits made during the period of demonetisation. Insofar as later issue is concerned the appellant alleges violation of principle

DCIT Central Circle-2(3), Mumbai vs. M/S. Sidh Granites Pvt. Ltd., Kolkata

ITA 996/MUM/2023[2018-19]Status: DisposedITAT Mumbai31 Aug 2023AY 2018-19

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhaildcit, Central Circle-2(3) Vs. M/S Sidh Granites Pvt. Room No. 803, 8 Th Floor, Ltd., 2Nd Floor, Room No. Pratishtha Bhavan, 21, 155B, Rabindra (Annexe), M.K.Road, Sarahi Burra Bazar, Churchgate, Kolkata – 400007 Mumbai - 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaecs2639G Appellant .. Respondent [ Appellant By : Anil Kumar Das Respondent By : Vimal Punamiya Date Of Hearing 15.06.2023 Date Of Pronouncement 31.08.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Revenue Is Directed Against The Order Passed By The Ld. Cit(A)-48, Mumbai, Dated 06.01.2023 For A.Y. 2018- 19. The Revenue Has Raised The Following Grounds Before Us: “1. Whether, On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit (A) Has Erred In Deleting The Addition On Account Of Bogus Unsecured Loan Of Rs. 8,82,00,000/- Treated As Unexplained Cash Credit In The Books Of The Assessee U/S 68 Of The Act. 2. The Appellant Craves Leave To Add, Delete, Alter, Modify, Rectify, Substitute Or Otherwise Any Or All Of The Grounds Of Appeal At Or Before The Time Of Hearing Of The Appeal. 3. The Appellant, Therefore, Prays That On The Grounds Stated Above, The Order Of The Ld. Cit (A), Mumbai, May Be Set Aside & That Of The Assessing Officer Restored.”

For Appellant: Anil Kumar DasFor Respondent: Vimal Punamiya
Section 132Section 133(6)Section 133ASection 148Section 68

erred in deleting the addition on account of bogus unsecured loan of Rs. 8,82,00,000/- treated as unexplained cash credit in the books of the assessee u/s 68 of the Act. 2. The appellant craves leave to add, delete, alter, modify, rectify, substitute or otherwise ... circumstances of the issue involved and evidences brought on record by the AO/appellant, the addition of Rs. 8,82,00,000/- as unexplained cash credit u/s 68 of the IT. Act is unjustified and unsustainable. There are ample judicial authorities supporting the above conclusion, some of which are highlighted

M/S Rameshkumar Vyas, Mumbai vs. ITO, Ward 26(2)(1), Mumbai

ITA 1978/MUM/2023[2009-2010]Status: DisposedITAT Mumbai31 Aug 2023AY 2009-2010

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2009-10

For Appellant: NoneFor Respondent: Smt. Mahita Nair (Sr. Ar.)
Section 131Section 142(1)Section 144Section 147Section 148Section 234Section 271(1)(c)

circumstances of the case and in law, the learned A.O. erred adding Rs 480000/ in respect of cash deposited in bank account as unexplained cash credits. 4. In the facts and the circumstances of the case and in law, the learned Commissioner of Income Tax(A) NFAC erred in confirming

Neworder Exports Pvt Ltd., Mumbai vs. ITO, Ward-5(2)(1), Mumbai

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

ITA 1821/MUM/2023[2012-13]Status: DisposedITAT Mumbai31 Aug 2023AY 2012-13
Section 143(3)Section 250

u/s.143(3) r.w.s. 147 of the Act, made the additions of Rs.39,39,900/- on account of gross profit and Rs.51,654/- as unexplained cash credit, against which the Assessee preferred first appeal before the ld. Commissioner, who though issued three notices to the Assessee at the e-mail address

Lalit Vithaldas Panchal, Mumbai vs. ITO Ward-29(2)(2), Mumbai

ITA 1355/MUM/2023[2016-2017]Status: DisposedITAT Mumbai31 Aug 2023AY 2016-2017
For Appellant: Shri Shashank Mehta, A.RFor Respondent: Shri B. Laxmi Kanth, D.R
Section 250Section 68

dated 20/04/2023 intrinsically following additions were upheld by Id. NFAC made by AO vide assessment order dated 17/12/2018:- a. Addition on account of unexplained cash credits u/s. 68 of the Act amounting to Rs.2,31,739/- 2. THAT, above mentioned ground are without prejudice to each other and appellant craves

Rehana Anwar Shaikh, Mumbai vs. Assessing Authority, Delhi

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

ITA 1606/MUM/2022[2014-15]Status: DisposedITAT Mumbai31 Aug 2023AY 2014-15

Bench: Shri B.R. Baskaran (Am) & Shri Sandeep Singh Karhail (Jm)

Section 10(38)Section 132Section 133(6)Section 68

assessed as taxable income of the assessee under section 68 of the Act. Accordingly, the Assessing Officer assessed the sale consideration as unexplained cash credit under section 68 of the Act. The learned CIT(A) confirmed the same. He also held that the profit earned by the assessee from sale ... documents furnished by the assessee. 16. We noticed earlier that the AO has assessed the Sale consideration of shares as unexplained cash credit u/s 68 of the Act. It is pertinent to note 10 Rehana Anwar Shaikh that the purchase of shares made in an earlier year has been accepted

Sonam Rajesh Rateria, Mumbai vs. ITO 18(3)(3), Mumbai

In the result, appeal filed by the Assessee stands allowed for statistical purpose

ITA 4030/MUM/2019[2011-12]Status: DisposedITAT Mumbai31 Aug 2023AY 2011-12

Bench: Shri N. K. Choudhry, Jm

For Appellant: Sh. Suchek AnchaliyaFor Respondent: Sh.. Anurag Tripathi, Ld. DR
Section 10(38)Section 143(1)Section 147Section 250Section 68

Assessee was show caused as to why entire sale consideration of Rs. 5,67,000/- from penny stock shall not be treated as unexplained cash credit u/s 68 of the Act and brought to tax under the head ‘income from other source’ by treating the same as transaction which ... capital gain of Rs. 497000/-“, decided the case of the Assessee and ultimately added the amount of Rs. 5,67,000/- as unexplained cash credit u/s 68 of the Act. 2 Sonam Rajesh Rateria 5. The Assessee being aggrieved preferred first appeal before the Ld. Commissioner, who on the same

J R Rice India Pvt. Ltd., Delhi vs. ACIT, Circle-13(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2852/DEL/2022[2017-18]Status: DisposedITAT Delhi31 Aug 2023AY 2017-18

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganeshassessment Year: 2017-18 J.R. Rice India Pvt. Ltd., Vs Acit, 5593/94, Lahori Gate, Main Road, Circle-13(1), Naya Bazar, New Delhi. Delhi. Pan: Aaccj1734F (Appellants) (Respondent) Assessee By : Shri Suresh K. Gupta, Ca Revenue By : Shri Anuj Garg, Sr. Dr Date Of Hearing : 10.05.2023 Date Of Pronouncement : 31.07.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.2852/Del/2022 For Ay 2017-18 Arise Out Of The Order Of The National Faceless Appeal Centre (Nfac) (Hereinafter Referred To As The ‘Ld. Cit(A)’) Dated 30.11.2022 In Din & Order No.Itba/Nfac/S/250/2022- 23/1047739597(1) Against The Order Of Assessment Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 27.12.2019 By The Assessing Officer, Circle-13(1), Delhi (Hereinafter Referred To As ‘Ld. Ao’). 2. The Only Effective Issue To Be Decided In This Appeal Is As To Whether The Ld.Cit(A) Was Justified In Confirming The Addition Made In The Sum Of Rs.52,60,000/- U/S 68 Of The Act R.W.S. 115Bbe Of The Act In Respect Of Cash Deposits Made During Demonetization Period, In The Facts & Circumstances Of The Instant Case.

For Appellant: Shri Suresh K. Gupta, CAFor Respondent: Shri Anuj Garg, Sr. DR
Section 143(3)Section 44ASection 68

make an addition of Rs.52,60,000/- in respect of cash deposits made in specified bank notes during the demonetization period as unexplained cash credit u/s 68 of the Act r.w.s. 115BBE of the Act. 4. It is not in dispute that the assessee company is maintaining regular books

Naynaba Ashoksinh Jedeja, Surat vs. Income Tax Officer, Ward-1(3)(8), Surat

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

ITA 423/SRT/2023[2016-17]Status: DisposedITAT Surat31 Aug 2023AY 2016-17

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.423/Srt/2023 Assessment Year: (2016-17) (Physical Hearing) Naynaba Ashoksinh Jadeja, Vs. The Ito, A/401, Nova Apex, Ward – 1(3)(8), B/H. Snehsankul Wadi, Adajan, Surat Anand Mahal Road, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Addpj2697Q (Appellant) (Respondent)

Section 143(3)Section 68

Delhi erred confirming the addition of Rs.34,10,000/- made by the Ld assessing officer treating the cash lying as safe custody as unexplained cash credit u/s 68 of the I.T. Act, 1961 without proper appreciating the fact of the case. ITA.423/SRT/2023/AY.2016-17 Naynaba Ashoksinh Jadeja 2. On the facts ... have accepted the explanation of the assessee, however without proper verifying the details, added the amount of Rs.34,10,000/- treating as unexplained cash credit u/s 68 of the Act. It ITA.423/SRT/2023/AY.2016-17 Naynaba Ashoksinh Jadeja is cleared that on 01.04.2015, the assessee has passed an adjustment entry wherein the safe

Raj Kishore HUF, Mumbai vs. I.T.O. Ward 31(3)(3), Mumbai

In the result, appeal filed by the Assessee stands allowed

ITA 1621/MUM/2023[2014-2015]Status: DisposedITAT Mumbai30 Aug 2023AY 2014-2015

Bench: Shri B.R. Baskaran, Am & Shri N. K. Choudhry, Jm

For Appellant: Shri Prakash JhunjhunwalaFor Respondent: Shri Surendra Kumar Meena
Section 10(38)Section 131Section 133(6)Section 143(1)Section 250

deposited in respondent's bank account. In view thereof, the CIT[A] found there was no reason to add the capital gains as unexplained cash credit under Section 68 of the Act. The tribunal while dismissing the appeals filed by the Revenue also observed on facts that these shares were

Shakuntala Kamble (Legal Representative of Premchand Kamble), Thane vs. DCIT -Cent. Cir `, Thane

ITA 1764/MUM/2021[2005-06]Status: DisposedITAT Mumbai30 Aug 2023AY 2005-06
For Appellant: Shri Pravin TembhekarFor Respondent: Shri K.C. Selvamani
Section 142Section 143(3)Section 144Section 147Section 153ASection 253(3)

IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

ACIT, Central Circle-3, Patna vs. Broadson Commodities Pvt Ltd, Dhanbad

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

ITA 63/PAT/2021[2017-18]Status: DisposedITAT Patna30 Aug 2023AY 2017-18

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 153Section 153C

Trailblazer Edusol (P) Limited and concurring his view with regard to A.Y. 2016-17, he made the addition of this amount as unexplained cash credit. Apart from this addition, he further observed that a document inventorized as GIB- 12, page no. 8 recovered during the search conducted on Subhash Prasad

ACIT, Central Circle-3, Patna vs. Broadson Commodities Pvt Ltd, Dhanbad

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

ITA 62/PAT/2021[2016-17]Status: DisposedITAT Patna30 Aug 2023AY 2016-17

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

Section 132Section 153Section 153C

Trailblazer Edusol (P) Limited and concurring his view with regard to A.Y. 2016-17, he made the addition of this amount as unexplained cash credit. Apart from this addition, he further observed that a document inventorized as GIB- 12, page no. 8 recovered during the search conducted on Subhash Prasad

Bueno Foods Private Limited, New Delhi vs. ACIT Circle-5(1), New Delhi

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

ITA 9241/DEL/2019[2016-17]Status: DisposedITAT Delhi30 Aug 2023AY 2016-17

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

Section 143(3)Section 56(2)(viib)Section 68

however ignored the same and concluded that assessee failed to discharge the genuineness of sundry creditors and proceeded to add the same as unexplained cash credit u/s 68 of the Act. 4.2. The ld. CIT(A) accepted the fact that all the details were furnished by the assessee

ITO, New Delhi vs. M/S. Samarth Fincap Services Pvt. Ltd., New Delhi

In the result, appeal of the revenue is partly allowed

ITA 276/DEL/2013[2007-08]Status: DisposedITAT Delhi30 Aug 2023AY 2007-08

Bench: Shri C.M. Garg & Dr. B. R. R. Kumarito, Vs. M/S. Samarth Fincap Services Ward-7(2), Pvt. Ltd, New Delhi F-2, Green Park Main, New Delhi (Appellant) (Respondent) Pan:Aabcs7132F Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Agarwal, Adv Revenue By: Shri Anuj Garg, Sr. Dr Date Of Hearing 06/07/2023 Date Of Pronouncement 30/08/2023

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Anuj Garg, Sr. DR
Section 131Section 68

facts and circumstances of the case, in deleting the addition of Rs. 2,40,00,000/- made by the AO as unexplained cash credits from undisclosed sources u/s 68 of the I.T. Act." 2. The Ld CIT(A) erred in law and on the facts and circumstances of the case