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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

Thakordas Parekh & Sons, Na vs. Arivs.Income Tax Officer, Ward-5, Navsari

In the result, ground No. 2 & 3

ITA 167/SRT/2022[2017-18]Status: DisposedITAT Surat30 Mar 2023AY 2017-18

Bench: Shri Pawan Singhआ.अ.सं./Ita No.167/Srt/2022 (Ay 2017-18) (Hearing In Physical Court) Thakordas Parekh & Sons Income Tax Officer, Ward-5, Bazar Street, Chikhli, Navsari, 204, 2Nd Floor, Vs Navsari-396530 Income Tax Office, Pan No: Aabft 4593 J Charpool, Awabaug, Navsari-396445 अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By Shri Rasesh Shah, C.A राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing 05.01.2023 उ"घोषणा क" तार"ख/Date Of 30.03.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Nfac/Ld.Cit(A)”] Dated 23.03.2022 For Assessment Year 2017-18, Which In Turn Arises From The Addition Made By The Income Tax Officer, Ward-5, Navsari / Assessing Officer In Assessment Order Passed Under Section 144 R.W.S143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 30.12.2019. The Assessee Has Raised The Following Grounds Of Appeal:- “1. On The Facts & In The Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Thakordas Parekh & Sons Of Assessing Officer In Rejecting The Books Of Accounts U/S 145(3) Of The Act.

Section 115BSection 144Section 145(3)Section 254(1)Section 68

confirming the action of Assessing Officer in making addition of Rs.18,07,500/- by rejecting the genuine cash sales and treating it as unexplained cash credit in the bank account u/s 68 of the Act. 3.On the facts and circumstances of the case as well as law on the subject ... such observation, the Assessing Officer issued show cause notice dated 20.12.2019 why the amount of Rs.18,07,500/- should not be treated as unexplained cash credits under section 68 of the Act and taxed under section 155BBE of the Act. The assessing officer recorded in the show cause notice that

M/S. Mega Aims, Bharuch vs. ITO, Ward-1(3), Bharuch

In the result, appeals filed by the Revenue (ITA Nos

ITA 751/SRT/2018[2014-15]Status: DisposedITAT Surat30 Mar 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.722 To 723/Srt/2018 Assessment Years: (2013-14 To 2014-15) (Physical Hearing) The Dcit, Circle-1, Vs. M/S. Mega Aims, Bharuch. B-1, Gokuldham Complex, Dahej By – Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.750 To 751/Srt/2018 Assessment Years: (2013-14 To 2014-15) M/S. Mega Aims, Vs. The Acit, Circle-1, B-1, Gokuldham Complex, Dahej By – Bharuch. Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) Shri Ashish Pophare, Cit(Dr) Appellant By Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 23/02/2023 Date Of Pronouncement 30/03/2023

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

officer held that assessee miserably failed to prove the genuineness of the creditors and therefore, made addition of Rs.6,53,30,728/-, as unexplained cash credit. 8. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A), who has partly allowed ... confirmation or PAN number with regard to other customers were furnished, the Assessing Officer treated the advances of Rs. 4890672/- as unexplained cash credit and added under Section 68 of the Act. Before the ld. CIT(A), the assessee made similar submission as made before us, which we have recorded

M/S. Mega Aims, Bharuch vs. ACIT, Circle-1, Bharuch

In the result, appeals filed by the Revenue (ITA Nos

ITA 750/SRT/2018[2013-14]Status: DisposedITAT Surat30 Mar 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.722 To 723/Srt/2018 Assessment Years: (2013-14 To 2014-15) (Physical Hearing) The Dcit, Circle-1, Vs. M/S. Mega Aims, Bharuch. B-1, Gokuldham Complex, Dahej By – Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.750 To 751/Srt/2018 Assessment Years: (2013-14 To 2014-15) M/S. Mega Aims, Vs. The Acit, Circle-1, B-1, Gokuldham Complex, Dahej By – Bharuch. Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) Shri Ashish Pophare, Cit(Dr) Appellant By Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 23/02/2023 Date Of Pronouncement 30/03/2023

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

officer held that assessee miserably failed to prove the genuineness of the creditors and therefore, made addition of Rs.6,53,30,728/-, as unexplained cash credit. 8. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A), who has partly allowed ... confirmation or PAN number with regard to other customers were furnished, the Assessing Officer treated the advances of Rs. 4890672/- as unexplained cash credit and added under Section 68 of the Act. Before the ld. CIT(A), the assessee made similar submission as made before us, which we have recorded

Deputy Commissioner of Income Tax, Bharuch Circle-1, Bharuch vs. M/S. Mega Aims, Bharuch

In the result, appeals filed by the Revenue (ITA Nos

ITA 723/SRT/2018[2014-15]Status: DisposedITAT Surat30 Mar 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.722 To 723/Srt/2018 Assessment Years: (2013-14 To 2014-15) (Physical Hearing) The Dcit, Circle-1, Vs. M/S. Mega Aims, Bharuch. B-1, Gokuldham Complex, Dahej By – Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.750 To 751/Srt/2018 Assessment Years: (2013-14 To 2014-15) M/S. Mega Aims, Vs. The Acit, Circle-1, B-1, Gokuldham Complex, Dahej By – Bharuch. Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) Shri Ashish Pophare, Cit(Dr) Appellant By Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 23/02/2023 Date Of Pronouncement 30/03/2023

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

officer held that assessee miserably failed to prove the genuineness of the creditors and therefore, made addition of Rs.6,53,30,728/-, as unexplained cash credit. 8. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A), who has partly allowed ... confirmation or PAN number with regard to other customers were furnished, the Assessing Officer treated the advances of Rs. 4890672/- as unexplained cash credit and added under Section 68 of the Act. Before the ld. CIT(A), the assessee made similar submission as made before us, which we have recorded

Deputy Commissioner of Income Tax, Bharuch Circle-1, Bharuch vs. M/S. Mega Aims, Bharuch

In the result, appeals filed by the Revenue (ITA Nos

ITA 722/SRT/2018[2013-14]Status: DisposedITAT Surat30 Mar 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.722 To 723/Srt/2018 Assessment Years: (2013-14 To 2014-15) (Physical Hearing) The Dcit, Circle-1, Vs. M/S. Mega Aims, Bharuch. B-1, Gokuldham Complex, Dahej By – Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) आयकर अपील सं./Ita Nos.750 To 751/Srt/2018 Assessment Years: (2013-14 To 2014-15) M/S. Mega Aims, Vs. The Acit, Circle-1, B-1, Gokuldham Complex, Dahej By – Bharuch. Pass Road, Bharuch. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm1615F (Appellant) (Respondent) Shri Ashish Pophare, Cit(Dr) Appellant By Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 23/02/2023 Date Of Pronouncement 30/03/2023

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

officer held that assessee miserably failed to prove the genuineness of the creditors and therefore, made addition of Rs.6,53,30,728/-, as unexplained cash credit. 8. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the ld. CIT(A), who has partly allowed ... confirmation or PAN number with regard to other customers were furnished, the Assessing Officer treated the advances of Rs. 4890672/- as unexplained cash credit and added under Section 68 of the Act. Before the ld. CIT(A), the assessee made similar submission as made before us, which we have recorded

Lakshmi Constructions, Nellore vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeals filed by the assessee are allowed for all the A

ITA 7/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam29 Mar 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.4/Viz/2023 To 7/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2013-14 To 2016-17) Sri Lakshmi Constructions, Vs. Deputy Commissioner Of Dr.No.26-3-560, Sln Towers Income Tax Iv Floor, B.V.Nagar Central Circle-1 Mini Bypass Road Guntur Nellore [Pan : Abofs2978J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri M.V.Prasad, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 02.03.2023 घोर्णध की तधरीख/Date Of Pronouncement : 29.03.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)], Visakhapatnam-3 Dated 30.11.2022 For The Assessment Years (A.Y.) 2013-14 To 2016-17. Since The Grounds Raised In These Appeals Are Common, These Appeals Are Clubbed, Heard Together & A Common Order Is Being Passed For The Sake Of Convenience As Under. Facts Are Extracted From I.T.A.4/Viz/2023 .

For Appellant: Shri M.V.Prasad, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR
Section 133ASection 143(3)Section 145

operations, the Assessing Officer (AO) made the following additions : 3 I.T.A. No.4/Viz/2023 to 7/Viz/2023, A.Y.2013-14 to 2016-17 Sri Lakshmi Constructions, Nellore 1. Unexplained cash credits : Rs.85,16,495/- 2. Estimation of income @8% on main contracts and 4% on sub contracts : Rs.66,31,375/- 3. Aggrieved by the additions ... firm preferred appeal before the CIT(A). The Ld.CIT(A), after considering the submissions made by the assessee, deleted the addition made towards unexplained cash credits of Rs.85,16,495/- and confirmed the estimation of profits made by the AO for Rs.66,31,375/-. Since the appeal filed

Lakshmi Constructions, Nellore vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeals filed by the assessee are allowed for all the A

ITA 6/VIZ/2023[2015-16]Status: DisposedITAT Visakhapatnam29 Mar 2023AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.4/Viz/2023 To 7/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2013-14 To 2016-17) Sri Lakshmi Constructions, Vs. Deputy Commissioner Of Dr.No.26-3-560, Sln Towers Income Tax Iv Floor, B.V.Nagar Central Circle-1 Mini Bypass Road Guntur Nellore [Pan : Abofs2978J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri M.V.Prasad, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 02.03.2023 घोर्णध की तधरीख/Date Of Pronouncement : 29.03.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)], Visakhapatnam-3 Dated 30.11.2022 For The Assessment Years (A.Y.) 2013-14 To 2016-17. Since The Grounds Raised In These Appeals Are Common, These Appeals Are Clubbed, Heard Together & A Common Order Is Being Passed For The Sake Of Convenience As Under. Facts Are Extracted From I.T.A.4/Viz/2023 .

For Appellant: Shri M.V.Prasad, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR
Section 133ASection 143(3)Section 145

operations, the Assessing Officer (AO) made the following additions : 3 I.T.A. No.4/Viz/2023 to 7/Viz/2023, A.Y.2013-14 to 2016-17 Sri Lakshmi Constructions, Nellore 1. Unexplained cash credits : Rs.85,16,495/- 2. Estimation of income @8% on main contracts and 4% on sub contracts : Rs.66,31,375/- 3. Aggrieved by the additions ... firm preferred appeal before the CIT(A). The Ld.CIT(A), after considering the submissions made by the assessee, deleted the addition made towards unexplained cash credits of Rs.85,16,495/- and confirmed the estimation of profits made by the AO for Rs.66,31,375/-. Since the appeal filed

Lakshmi Constructions, Nellore vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeals filed by the assessee are allowed for all the A

ITA 5/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam29 Mar 2023AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.4/Viz/2023 To 7/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2013-14 To 2016-17) Sri Lakshmi Constructions, Vs. Deputy Commissioner Of Dr.No.26-3-560, Sln Towers Income Tax Iv Floor, B.V.Nagar Central Circle-1 Mini Bypass Road Guntur Nellore [Pan : Abofs2978J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri M.V.Prasad, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 02.03.2023 घोर्णध की तधरीख/Date Of Pronouncement : 29.03.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)], Visakhapatnam-3 Dated 30.11.2022 For The Assessment Years (A.Y.) 2013-14 To 2016-17. Since The Grounds Raised In These Appeals Are Common, These Appeals Are Clubbed, Heard Together & A Common Order Is Being Passed For The Sake Of Convenience As Under. Facts Are Extracted From I.T.A.4/Viz/2023 .

For Appellant: Shri M.V.Prasad, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR
Section 133ASection 143(3)Section 145

operations, the Assessing Officer (AO) made the following additions : 3 I.T.A. No.4/Viz/2023 to 7/Viz/2023, A.Y.2013-14 to 2016-17 Sri Lakshmi Constructions, Nellore 1. Unexplained cash credits : Rs.85,16,495/- 2. Estimation of income @8% on main contracts and 4% on sub contracts : Rs.66,31,375/- 3. Aggrieved by the additions ... firm preferred appeal before the CIT(A). The Ld.CIT(A), after considering the submissions made by the assessee, deleted the addition made towards unexplained cash credits of Rs.85,16,495/- and confirmed the estimation of profits made by the AO for Rs.66,31,375/-. Since the appeal filed

Lakshmi Constructions, Nellore vs. Deputy Commissioner of Income Tax, Central Circle-1, Guntur

In the result, appeals filed by the assessee are allowed for all the A

ITA 4/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam29 Mar 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.4/Viz/2023 To 7/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2013-14 To 2016-17) Sri Lakshmi Constructions, Vs. Deputy Commissioner Of Dr.No.26-3-560, Sln Towers Income Tax Iv Floor, B.V.Nagar Central Circle-1 Mini Bypass Road Guntur Nellore [Pan : Abofs2978J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri M.V.Prasad, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 02.03.2023 घोर्णध की तधरीख/Date Of Pronouncement : 29.03.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: These Appeals Are Filed By The Assessee Against The Orders Of Commissioner Of Income Tax (Appeals) [Cit(A)], Visakhapatnam-3 Dated 30.11.2022 For The Assessment Years (A.Y.) 2013-14 To 2016-17. Since The Grounds Raised In These Appeals Are Common, These Appeals Are Clubbed, Heard Together & A Common Order Is Being Passed For The Sake Of Convenience As Under. Facts Are Extracted From I.T.A.4/Viz/2023 .

For Appellant: Shri M.V.Prasad, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR
Section 133ASection 143(3)Section 145

operations, the Assessing Officer (AO) made the following additions : 3 I.T.A. No.4/Viz/2023 to 7/Viz/2023, A.Y.2013-14 to 2016-17 Sri Lakshmi Constructions, Nellore 1. Unexplained cash credits : Rs.85,16,495/- 2. Estimation of income @8% on main contracts and 4% on sub contracts : Rs.66,31,375/- 3. Aggrieved by the additions ... firm preferred appeal before the CIT(A). The Ld.CIT(A), after considering the submissions made by the assessee, deleted the addition made towards unexplained cash credits of Rs.85,16,495/- and confirmed the estimation of profits made by the AO for Rs.66,31,375/-. Since the appeal filed

M/S. Bajrangbali Steel Industries Pvt. Ltd, Rourkla vs. ACIT, Central Circle, Sambalpur

In the result, appeals of the assessee in IT(SS)A No

ITA 109/CTK/2022[2020-21]Status: DisposedITAT Cuttack28 Mar 2023AY 2020-21

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.31 To 33/Ctk/2022 (ननधाारण वषा / Assessment Year : 2016-2017 To 2018-2019) M/S Bee Pee Rollers Pvt. Ltd., Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3593 P & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.34 To 39/Ctk/2022 & आयकर अऩीऱ/Ita No.109/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2017 To 2020-2021) M/S Bajrangbali Steel Industries Pvt. Vs Acit, Central Circle, Sambalpur Ltd., Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aabcb 3594 L & आयकर अऩीऱ (तऱाशियाां और अशिग्रहण)/It(Ss)A Nos.40 To 44/Ctk/2022 (ननधाारण वषा / Assessment Year : 2014-2015 To 2018-2019) M/S Bajrangbali Re-Rollers Pvt. Ltd. Vs Acit, Central Circle, Sambalpur Lal Building, Kachery Road, Rourkela, Sundergarh, Odisha-769012 Pan No. :Aaccb 6678 A (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate With Shri B.K. Tibrewal, Ca & Ms. Nisha Rachh, Ca Shri M.K.Gautam, Pr.Cit(Osd) राजस्व की ओर से /Revenue By : सुनवाई की तारीख / Date Of Hearing : 28/03/2023 घोषणा की तारीख/Date Of Pronouncement : 28/03/2023

For Appellant: Shri S.K.Tulsiyan, Advocate with Shri
Section 133ASection 153ASection 292CSection 69Section 69C

made an addition thereafter. It was the further submission that on similar lines sales to certain concerns were also treated as unexplained cash credits and additions had been made on such sales. It was the further submission that on the basis of information received from DDIT(Inv.), Unit ... Kolkata, the transaction of loans received by the assessee from various financial companies were treated as the unexplained cash credits in the hands of the assessee by invoking the provisions of Section 69 of the Act and additions were made thereafter. It was the submission that all the purchases