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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

Smt. Satyawati Marwaha Through Legal Heir Sh, Chander Sheikhar Marwaha, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result, the appeal for Asstt

ITA 347/ASR/2024[2015-16]Status: DisposedITAT Amritsar30 Oct 2025AY 2015-16

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

were issued and shares were also sold on stock exchange and, accordingly, held that there was no reason to add capital gains as unexplained cash credit under section 68 - Whether Tribunal had rightly concluded that there was no merit in appeal against Commissioner (Appeals) order - Held, yes [Para

Smt. Satyawati Marwaha Through Legal Heir Sh. Chander Sheikhar Marwaha, Jalandhar vs. Assistant Commissioner of Income Tax, Jalandhar

In the result, the appeal for Asstt

ITA 346/ASR/2024[2014-15]Status: DisposedITAT Amritsar30 Oct 2025AY 2014-15

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, C. A
Section 10(38)Section 132Section 144Section 144rSection 147Section 148Section 151Section 250(6)Section 68

were issued and shares were also sold on stock exchange and, accordingly, held that there was no reason to add capital gains as unexplained cash credit under section 68 - Whether Tribunal had rightly concluded that there was no merit in appeal against Commissioner (Appeals) order - Held, yes [Para

Samir Kumar Paikaray, Khurda vs. Income Tax Officer, Khurda

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

ITA 382/CTK/2025[2017-18]Status: DisposedITAT Cuttack30 Oct 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 382/Ctk/2025 Assessment Year: 2017-2018 Samir Kumar Paikaray,………….………….,…Appellant Sriram Nagar, Khurdha, Dist. Khurda-752022, Odisha [Pan:Ahcpp4275D] -Vs.- Income Tax Officer,……………………….…....Respondent Khurda Ward, Khurda, Dist. Khurda-752022, Odisha Appearances By: Shri K.K. Bal, Advocate, Appeared On Behalf Of The Assessee Shri Vijay Singh, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 03, 2025 Date Of Pronouncing The Order: October 30, 2025 O R D E R

Section 133(6)Section 143(2)Section 68

asked to explain as to why the cash deposits of 3 Samir Kumar Paikaray Rs.5,08,000/- should not be treated as unexplained cash credit under section 68 of the Act. The assessee furnished a reply stating that cash deposit of Rs.4,88,000/- consisting of 488 numbers ... Rs.86,83,190/-, which reads as under:- Income as per IT return Rs.13,78,690/- (+) Income from other Rs.57,24,640/- sources being unexplained cash credit under section 68 (+)Income from other Rs.5,08,000/- sources being unexplained cash credit under section 68 representing deposit of SBN (+) Addition on account

Apex Irrigation, Rajkot vs. Commissioner of Income Tax Appeals, National Faceless Assessment Centre, Delhi

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

ITA 94/RJT/2025[2017-2018]Status: DisposedITAT Rajkot30 Oct 2025AY 2017-2018

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri Brijesh Parekh, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 253(5)Section 40Section 5Section 68

short “the Act”), vide order dated 16.12.2019 2. The Grounds of appeal raised by the assessee are as follows: 1. Unexplained Cash Credit u/s. 68 2. Expenditure Disallowed u/s. 40(a)(ia) 3. Expenditure disallowed as revenue and treated as capital expenditure Apex Irrigation 3. At the outset, that

Sanjay Sivabhagwan Keyal, Surat vs. ITO, Ward-2(3)(4), Surat

In the result, the appeal of the assessee is dismissed

ITA 636/SRT/2025[2009-10]Status: DisposedITAT Surat30 Oct 2025AY 2009-10

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Sanjay Sivabhagwan Keyal Ito, Ward – 2(3)(4), Flat No.304, 3Rd Floor, Room No.613, Vatika Township, Near Model, Vs. Aaaykar Bhavan, Township, Parvat Patia Majura Gate, Surat - 395010. Surat - 395002. Pan No. Adspk 6097N Appellant Respondent

For Appellant: Shri J.K. Chandnani, Sr. DRFor Respondent: Mr. Rasesh, CA
Section 144Section 148Section 69A

officer by sustaining addition of Rs. 13,49,835/ out of total addition of Rs. 13,91,940/- u/s. 69A on account of unexplained cash credit. u/s. 69A on account of unexplained cash credit. u/s. 69A on account of unexplained cash credit. 3. It is prayed that the assessment framed

Mr. Anil, Ernakulam vs. ITO Non Corp Ward-1(1), Kochi

In the result, the appeals of the assessee bearing ITA Nos 614 &

ITA 615/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri C.V. Vishnu Das KFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 250Section 271A

filed in response to notice U/s 148 of the Act. The assessment was completed with addition of Rs.1,50,92,230/- as unexplained cash credit. Being aggrieved, the assessee challenged the impugned assessment order before the Ld. CIT(A). However, the appeal was filed with a delay of 254 days

Mr. Anil, Ernakulam vs. ITO, Non Corp Ward-1(10, Kochi

In the result, the appeals of the assessee bearing ITA Nos 614 &

ITA 614/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri C.V. Vishnu Das KFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 250Section 271A

filed in response to notice U/s 148 of the Act. The assessment was completed with addition of Rs.1,50,92,230/- as unexplained cash credit. Being aggrieved, the assessee challenged the impugned assessment order before the Ld. CIT(A). However, the appeal was filed with a delay of 254 days

Dy. Commissioner of Income Tax, Jaipur vs. Hem Chand Jain, Jaipur

In the result, appeal of the Revenue is dismissed and Cross Objection of the assessee is allowed

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &
Section 147Section 148Section 148ASection 151Section 250

which is used for routing unaccounted fund of beneficiaries. Accordingly, the AO made addition of Rs. 3,28,75,293/- on account of unexplained cash credit under section 69A of the IT Act, 1961 and addition of Rs. 6,57,506/- on account of alleged commission paid under section

ITO, Ward-4(2)(3), Ahmedabad vs. Maheshwari Sales Corporation, Ahmedabad

In the result, the appeal filed by the Revenue stands dismissed

ITA 1306/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2018-19

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1306/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Ito Maheshwari Sales Corporation बनाम/ Ward-4(2)(3) C-111, Ganesh Meridin V/S. Ahmedabad Nr.Sola Bridge, Sola Ahmedabad-380 058 "थायी लेखा सं./Pan: Aalfm 4917 H (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/09/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 11/04/2025, Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Revenue Has Raised The Following Grounds Of Appeal: Ito Vs. Maheshwari Sales Corporation Asst. Year : 2018-19

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 132Section 147Section 250Section 68

held that the assessee had taken accommodation entries of bogus sales aggregating Rs. 63,84,998/-. Consequently, the said sum was treated as unexplained cash credit under section 68 of the Act and added to the total income of the assessee. 4. In appeal before CIT(Appeals), the assessee submitted ... that the Assessing Officer had made an addition of Rs. 63,84,998/- under section 68 of the Act treating the same as unexplained cash credit on the allegation that the assessee had taken accommodation entries from M/s. Kushal Tradelink Ltd. and its associates. The Assessing Officer primarily relied

Rohit Prakashchandra Shah, Ahmedabad vs. The Income Tax Officer, Ward-1(2)(3), Ahmedabad

In the result, appeal preferred by the assessee is dismissed

ITA 128/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2014-15

Section 147Section 148

made by the assessee as accommodation entry and the entire sale proceeds of shares amounting to Rs.1,88,34,063/- was held as unexplained cash credit of the assessee. The assessment was completed under Section 147 r.w.s. 144B of the Act on 29.03.2022 at a total income of Rs.1

Amit Suresh Agrawal, Satara vs. ITO Ward-2, Satara

In the result, appeal of the assessee is partly allowed

ITA 2225/PUN/2025[2016-17]Status: DisposedITAT Pune30 Oct 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149(1)(b)Section 151Section 151ASection 153ASection 153CSection 250Section 271(1)(c)Section 68

Income Tax Act, 1961 in respect of cash deposited in the bank account. The impugned addition does not represent any unexplained cash credit as envisaged under Section 68 of the Act. Section 68 is not attracted in this case. The addition is wholly unjustified and deserves to be deleted

Yamini Arjan Bharwani, Kolkata vs. ITO, Ward 30(1), Kolkata

Appeal of the assessee is allowed for statistical purposes

ITA 800/KOL/2025[2017-2018]Status: DisposedITAT Kolkata30 Oct 2025AY 2017-2018

Bench: April 1, 2012. No restriction on the premium-to-sum assured ratio was there. The policy was purchased by appellant on 29.01.2011 For exemption under Section 10(10D), the amount must be received as part of a matured policy or a payment on the occurrence of a specified contingency (e.g., death of the insured). In the case of premature termination (e.g. surrender of ULIP), the exemption will still be available if the conditions (e.g, death of the insured) above are met. Presently, the pre matu

Section 10Section 10(100)Section 250

basis of following findings: “4.4 As regards, the grounds relating to the Ld. ITO has erred in adding the cash deposit as unexplained cash credit of Rs 1600000 and not giving the exemption u/s 10(10D) of amounting to Rs. 16,01,284/- where as it is quite clear that

Tantia Agrochemicals Pvt. Ltd., Kolkata vs. DCIT, Circle 4(2), Kolkata

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

ITA 1232/KOL/2025[2013-2014]Status: DisposedITAT Kolkata30 Oct 2025AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 250Section 68

confirming the addition made by the AO to the tune of Rs. 9,00,00,000/- on account of share capital as unexplained cash credit u/s 68 of the Income Tax Act, 1961 without going into the merits of the addition 4.) That on the facts and in the circumstances ... erred in confirming the addition made by the AO to the tune of Rs. 96,55,531/- on account of unsecured loan as unexplained cash credit u/s 68 of the Income Tax Act, 1961 without going into the merits of the addition. 5.) That the appellant craves leave

Income Tax Officer, Ward-7(2)(3), Bengaluru vs. Mohammed Farooq Kanana, Bengaluru

In the result, appeal filed by the Revenue is dismissed

ITA 1509/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Oct 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri.Soundararajan Kassessment Year : 2020-21 Ito, Vs. Mr. Mohammed Farooq Kanana, 6 9Th Cross, H Siddaiah Road, Ward – 7(2)(3), Bangalore. Bangalore – 560 027, Karnataka. Pan : Abvpm 1212 A Appellant Respondent Assessee By : Shri. Thirumala Naidu, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 27.10.2025 Date Of Pronouncement : 30.10.2025

For Appellant: Shri. Thirumala Naidu, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 147Section 250

time of assessment and considering the submission of the assessee before the verification unit amount of Rs.1,20,16,900/- was treated as unexplained cash credit under section 68 of the Act and applied section 115BBE of the Act. 8. Aggrieved from the above Order, assessee filed appeal before ... does not have strong footing and requires to be deleted. Accordingly, the addition of Rs.1,20,16,900/- u/s 68 as unexplained cash credit is deleted and the ground of appeal is allowed.” 9. Aggrieved from the above Order of the learned CIT(A), Revenue filed appeal before the Tribunal

ACIT, Cir.20(1), Mumbai vs. Girish Shamji Chheda, Mumbai

In the result, the revenue's appeal is dismissed

ITA 3123/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Oct 2025AY 2020-21

Bench: Shri Pawan Singh & Smt.Renu Jauhri

For Appellant: Shri Fenil Bhatt, AdvFor Respondent: Shri Swapnil Choudhary- Sr. AR
Section 143(3)Section 250Section 36(1)(iii)Section 57Section 68

facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition made u/s.68 as unexplained cash credits of Rs.3,61,16,600/- without apprecinting the fact that the assessee failed to prove the genuineness and creditworthiness of transactions of unsecured loans when ... Following additions were made to the returned income: i. Disallowance u/s.36(1)(iii) -1,47,99,790/- ii. Unexplained Cash Credits u/s.68 -36,116,600/- Page 3 ITA NO. 3123/mum/2025. Aggrieved, the assessee preferred an appeal before ld. CIT(A). Vide order dated 21.09.2022, ld. CIT(A) allowed the assessee

Kbj Developers Pvt Ltd, Mumbai vs. Asst Commisioner of Income Tax- 4(2)(1), Mumbai

ITA 1837/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Oct 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 133(6)Section 142Section 143(1)Section 143(2)Section 250

establish the genuineness and creditworthiness of unsecured loans", finally treated the amount of Rs.35,14,90,958/- in total, as unexplained cash credit taxable u/sec. 68 of the Act. 10. The AO also by perusing the AIR information also noticed that Assessee has sold a property i.e. Plot ... Whether on the facts and circumstances of the case, the Ld.CIT(A)/ NFAC is right in deleting the disallowance made by AO as unexplained cash credit of Rs.34,65,46,958/- u/s 68 of the Act? 3) Whether on the facts and, circumstances of the case, the Ld.CIT(A)/NFAC

Assistant Commissioner of Income Tax - Circle-4(2)(1), Mumbai vs. Kbj Developers Private Limited, Mumbai

In the result, appeal filed by the Revenue is dismissed and

ITA 1409/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Oct 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry

For Respondent: Shri Satyaprakash Singh, Ld. CA
Section 133(6)Section 142Section 143(1)Section 143(2)Section 250

establish the genuineness and creditworthiness of unsecured loans”, finally treated the amount of Rs. 35,14,90,958/- in total, as unexplained cash credit taxable u/sec. 68 of the Act. 10. The AO also by perusing the AIR information also noticed that Assessee has sold a property i.e. Plot ... Whether on the facts and circumstances of the case, the Ld.CIT(A)/ NFAC is right in deleting the disallowance made by AO as unexplained cash credit of Rs. 34,65,46,958/- u/s 68 of the Act? 3) Whether on the facts and, circumstances of the case, the Ld.CIT

Prem Tube Co. Pvt Ltd., Delhi vs. ITO Ward 20(1), Delhi

ITA 6005/DEL/2025[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Sh. Satbeer Singh Godaraita No. 6004/Del/2025 : Asstt. Year : 2018-19 Ita No. 6005/Del/2025 : Asstt. Year : 2019-20 Prem Tube Co. Pvt. Ltd., Vs Income Tax Officer, Pranshu Goel, Chartered Accountant, Ward-20(1), 5A/3A, Ansari Road, Darya Ganj, New Delhi- New Delhi-110002 (Appellant) (Respondent) Pan No. Aaccp8284C Assessee By: Sh. Aditya Gupta, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order These Assessee’S Twin Appeals In Ita Nos. 6004 & 6005/Del/2025 For Assessment Years 2018-19 & 2019-20, Arise Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1079370154(1) & 1079370333(1) Both Dated 07.08.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Aditya Gupta, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 37Section 68

learned lower authorities have erred in law and on facts in treating it’s varying purchases sourced from M/s GS Industries as unexplained cash credits u/s 68, in the Prem Tube Co. Pvt. Ltd. assessments in question as upheld in the lower appellate discussion. 4. It is in this factual ... counsel lastly argues that both the lower authorities have erred in law and on facts in adding the impugned bogus purchases claimed as unexplained cash credits. The Revenue could hardly dispute that this is an expenditure claim rather than credit entries in the assessee’s books of account forming subject

Prem Tube Co. Pvt Ltd, Delhi vs. ITO Ward 20(1), Delhi

ITA 6004/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Oct 2025AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 6004/Del/2025 : Asstt. Year : 2018-19 Ita No. 6005/Del/2025 : Asstt. Year : 2019-20 Prem Tube Co. Pvt. Ltd., Vs Income Tax Officer, Pranshu Goel, Chartered Accountant, Ward-20(1), 5A/3A, Ansari Road, Darya Ganj, New Delhi- New Delhi-110002 (Appellant) (Respondent) Pan No. Aaccp8284C Assessee By: Sh. Aditya Gupta, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order These Assessee’S Twin Appeals In Ita Nos. 6004 & 6005/Del/2025 For Assessment Years 2018-19 & 2019-20, Arise Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1079370154(1) & 1079370333(1) Both Dated 07.08.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: Sh. Aditya Gupta, AdvFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 147Section 37Section 68

learned lower authorities have erred in law and on facts in treating it’s varying purchases sourced from M/s GS Industries as unexplained cash credits u/s 68, in the Prem Tube Co. Pvt. Ltd. assessments in question as upheld in the lower appellate discussion. 4. It is in this factual ... counsel lastly argues that both the lower authorities have erred in law and on facts in adding the impugned bogus purchases claimed as unexplained cash credits. The Revenue could hardly dispute that this is an expenditure claim rather than credit entries in the assessee’s books of account forming subject

Sh Raj Kumar, Haryana vs. ITO Ward -5, Rohtak

Appeal is allowed in the aforesaid terms

ITA 5449/DEL/2025[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Raj Kumar, Vs. Ito, Ward-5, 1107/34, Vijay Nagar, Rohtak Rohtak-124001 Haryana (Pan: Bfypk0435H) (Appellant) (Respondent) Appellant By : Sh. Lalit Mohan, Ca Respondent By : Sh. Manoj Kumar, Sr. Dr.

For Appellant: Sh. Lalit Mohan, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 115BSection 143(3)Section 68

demonetized currency. Since Essar company is not the public sector oil company, AO made the addition of Rs. 34,30,729/- as unexplained cash credit u/s. 68 of the Act by passing order u/s. 143(3) of the Act. However, in appeal, Ld. First Appellate Authority sustained the addition. Against ... books of accounts then both logically and legally, such sales could not be separately assessed to tax as bogus sales and unexplained cash credit u/s. 68 of the Act. It was further submitted that Ld. CIT(A) has failed to appreciate that once the purchase declared in the books