“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

Dy. Commissioner of Income-Tax, Central Circle-1, Visakhpatnam vs. M/S. Sardar Projects Pvt. Ltd, Visakhapatnam

In the result, appeal of the revenue is dismissed

ITA 357/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam04 Sept 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 357/Viz/2025 (A.Y. 2021-22) Dcit – Central Circle – 1 V. M/S. Sardar Projects Pvt Ltd., 5Th Floor, Direct Taxes Building 7-5-64, Plot No. 48 Mvp Colony, Visakhapatnam – 530017 Pandurangarpuram Andhra Pradesh Visakhapatnam – 530003 Andhra Pradesh [Pan:Aakcs3773K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 36(1)(iii)Section 69A

that since the nature and source have been duly accepted by the Ld.AO it can be construed as business receipts and not be unexplained cash credits u/s. 69 of the Act. The Ld.CIT(A) also relied on the decision of the jurisdictional Tribunal in the case of DCIT

ACIT, Range-1, Lucknow vs. Shri Pankaj Verma, Lucknow

In the result, I.T.A. No.390/Lkw/2020 is partly allowed while I

ITA 430/LKW/2020[2017-18]Status: DisposedITAT Lucknow04 Sept 2025AY 2017-18

Bench: Shri Subhash Malguria & Shri Nikhil Choudhary

Section 142(1)Section 143(2)Section 143(3)Section 68

that he was not satisfied with the explanation furnished by the assessee. She, therefore, added back a sum of Rs.97,24,780/- as unexplained cash credit in the hands of the assessee and brought the same to tax u/s 115BBE of the Act. She also initiated penalty proceedings u/s 271AAC

Shri Pankaj Verma, Lucknow vs. DCIT, Range-1, Lucknow

In the result, I.T.A. No.390/Lkw/2020 is partly allowed while I

ITA 390/LKW/2020[Shri Pankaj Verma]Status: DisposedITAT Lucknow04 Sept 2025

Bench: Shri Subhash Malguria & Shri Nikhil Choudhary

Section 142(1)Section 143(2)Section 143(3)Section 68

ITO, Patiala vs. Sh. Kamalpreet Singh, Patiala

Appeal stands dismissed

ITA 225/CHANDI/2015[2009-10]Status: DisposedITAT Chandigarh04 Sept 2025AY 2009-10

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.224/Chandi/2015 (िनधा"रणवष" / Assessment Year: 2009-10) Acit-Circle Patiala Shri Balwinder Singh Patiala. Prop. M/S M.P. Traders बनाम/ Vs. (Represented By L/R Shri Simranpal Singh) # 986/3 Dhobi Ghat, Patiala. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acrps-5840-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. Co. No.13/Chandi/2015 [In Ita No.224/Chandi/2015] (िनधा"रणवष" / Assessment Year: 2009-10) Shri Balwinder Singh Acit-Ward-1 बनाम/ Prop. M/S M.P. Traders Patiala. (Represented By L/R Shri Simranpal Singh) Vs. # 986/3 Dhobi Ghat, Patiala. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acrps-5840-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकरअपीलसं./ Ita No.225/Chandi/2015 (िनधा"रणवष" / Assessment Year: 2009-10) Acit-Circle Patiala Shri Kamalpreet Singh बनाम/ Vs. Patiala. Prop. M/S Saran Enterprises 4, Dlf Shopping Complex, Patiala. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Acbps-1831-N (अपीलाथ"/Appellant) : (""थ" / Respondent)

For Appellant: Shri Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 120(1)Section 133ASection 143(2)Section 143(3)

assessee against purchases and in such a case, provisions of Sec.68 would have no application. These provisions would apply only when there is unexplained cash credit which is not the case here. These creditors represent payables against purchase of trading goods by the assessee. Further, these creditors have duly been

ITO, Patiala vs. Sh. Balwinder Singh, Patiala

Appeal stands dismissed

ITA 224/CHANDI/2015[2009-10]Status: DisposedITAT Chandigarh04 Sept 2025AY 2009-10

For Appellant: Shri Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 120(1)Section 133ASection 143(2)Section 143(3)

Sh. Kamalpreet Singh, Patiala vs. ACIT, Patiala

Appeal stands dismissed

ITA 185/CHANDI/2015[2009-10]Status: DisposedITAT Chandigarh04 Sept 2025AY 2009-10

For Appellant: Shri Tejmohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 120(1)Section 133ASection 143(2)Section 143(3)

Income Tax Officer, Ward-1(3)(1), Ahmedabad vs. Rajeshkumar Rameshchandra Shah, Ahmedabad

In the result, appeal filed by the Revenue is dismissed

ITA 1074/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2017-18

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Alpesh Parmar, CIT. DRFor Respondent: Shri Tushar Hemani, Sr. Advocate &

Section 250Section 68

grounds raised by the Revenue are as under: 1. "CIT(A) has erred in deleting the addition made on account of unexplained cash credit u/s 68 of the Act Rs. 9,60,01,000/- without appreciating the findings brought out by the assessing officer in the assessment order ... relevant year as compared to early years. The AO has not considered this aspect by holding the cash deposit during demonetization period as unexplained cash credit in the books of the appellant. It is the fact that the appellant is in the jewellery/ bullion business for more than 20 years

Trikkur Varadarajan Sreenivasan, Hyderabad vs. Income Tax Officer, Ward-1(1), Hyderabad

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

ITA 786/HYD/2025[2021-22]Status: DisposedITAT Hyderabad04 Sept 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: MS. Jyothi Anumolu, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 142(1)Section 143(3)Section 250Section 68

cause notice dated 21.09.2023. Since, there were no proper explanation from the assessee, the Assessing Officer made addition in respect of variation of unexplained cash credits amounting to Rs.1,96,41,385/- u/sec.68 of the Income Tax Act, 1961, addition on account of disallowance of deduction of HRA amounting ... record. In the present case, although, the assessee has furnished certain details before the Assessing Officer in respect of additions made towards unexplained cash credits u/sec.68 of the Income Tax Act, 1961, but, the learned CIT(A) not even considered the said information while disposing of the appeal. Since

Income Tax Officer Ward-3(3)(2), Ahmedabad vs. Manthan Shyam Ganatra, Ahmedabad

In the result, appeal filed by the Revenue is dismissed

ITA 2032/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Sept 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Yogesh Mishra, Sr.DRFor Respondent: Shri Sunil Maloo, AR

Section 139(1)Section 139(4)Section 148Section 148ASection 250Section 68

assessee, added all credit entries except credit on account of sale of property and credit on account of professional receipts, as unexplained cash credit of the appellant u/s 68. 2.1 It is worthwhile to go through the reason cited by the AO for proposing such disallowance. At the time ... documentary evidence. In the absence of the same, a show cause notice was sent to tax the amount of Rs.96,03,867/- as unexplained cash credit u/s 68 of the Act.” 2.2 After the above mentioned show cause notice, the assessee not only availed opportunity of video conferencing to explain

Forum Viniyog Pvt. Ltd., Kolkata vs. ITO, Ward-8(2), Kolkata

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

ITA 1338/KOL/2025[2012-13]Status: DisposedITAT Kolkata03 Sept 2025AY 2012-13

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250Section 68

confirming the AO's action of adding the refund of advance redemption proceeds of Rs.5,41,00,000/- by way of unexplained cash credit u/s 68 of the Act. (b) For that on the facts and in the circumstances of the case, the authorities below failed to appreciate that ... redeemed and repaid by M/s Forum Real Estate Pvt Ltd during the year and therefore the said proceeds cannot be regarded as unexplained cash credit u/s 68 of the Act. (c) For that on the facts and in the circumstances of the case, the authorities below failed to appreciate that

Arumugam Pavalakkodi, Villupuram vs. ITO, Ward-2, Villupuram

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

ITA 1822/CHNY/2025[2011-12]Status: DisposedITAT Chennai03 Sept 2025AY 2011-12

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1822/Chny/2025 Assessment Years: 2011-12 Arumugam Pavalakkodi, Income Tax Officer, No.76 Salem Main Road, Chinnasalem, Ward-2, Kallakkurichi, Villupuram, Villupuram. Tamil Nadu-606 201. [Pan: Brupp8511R] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.S.Sridhar, Advocate. प्रत्यर्थी की ओर से /Revenue By : Shri Veeramany K, Irs सुनवाई की तारीख/Date Of Hearing : 25.08.2025 घोषणा की तारीख /Date Of Pronouncement : 03.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M : This Appeal Is Filed By The Assessee Against The Order Bearing Din & Order No.Itba / Nfac / S / 250 / 2022-23 / 1051051140(1) Dated 21.03.2023 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), National Faceless Appeal Center[Nfac], Delhi, For The Assessment Year 2011-12. The Reference To The Word “Act” In This Order Hereinafter Shall Mean The Income Tax Act, 1961 As Amended From Time To Time.

For Appellant: Mr.S.Sridhar, AdvocateFor Respondent: Shri Veeramany K, IRS

assessee. It was submitted that the only issue under consideration is an addition of Rs.1,62,70,626/- on account of unexplained cash credits in assessee’s bank account. The impugned addition was made by the Ld.AO for want of any submission and details Page - 2 - of 5 ITA No.1822

Shree Salasar Investments Limited, Nariman Point, Mumbai vs. Income Tax Officer - Ward 3(3)(2), Mumbai

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

ITA 3486/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Sept 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjeeshree Salasar Investments Vs Income-Tax Officer-Ward 3(3)(2), Limited, Aayakar Bhavan, M.K.Road, 1111-A, Raheja Chambers, 12Th Mumbai-400 020 Floor, Nariman Point, Mumbai- 400 021 Pan: Aaccs6412G Appellant Respondent

For Appellant: Shri Ravikant Pathak, C.AFor Respondent: Ms. Kavitha Kaushik (SR DR)

Section 143(3)Section 250Section 68

duly supported by the documentary evidence. However, the AO did not accept the contentions of the Appellant and added Rs.63,30,000/-as unexplained cash credit u/s 68 of the Income Tax Act. Your Appellant craves leave to add, to alter or to amend the aforesaid statement of facts ... Rs.63,30,000/-(i.e.Rs 27,30,000/- Plus Rs.3 6,00,000/-) being Share Capital and Share Premium received from two parties, as unexplained cash credit u/s 68 of the Act. The Appellant submit that on the facts and circumstances of the case, the identity. creditworthiness of the share holder

Deputy Commissioner of Income Tax, Circle-1(1), New Delhi, Delhi vs. Agya Imports Limited, Delhi

In the result, appeals of Revenue in ITA Nos

ITA 3755/DEL/2024[2015-16]Status: DisposedITAT Delhi03 Sept 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rakesh Sehgal, CAFor Respondent: Shri Anurag S. Daria, Sr. DR

Section 144BSection 147Section 148Section 68Section 69ASection 69C

case, the Ld. CIT(A) has erred in deleting the addition of Rs. 1,70,04,498/- on the account of unexplained cash credit u/s 68 of IT Act, 1961 without appreciating the fact that the Entry Provider himself has stated on Page ... case, the Ld. CIT(A) has erred in deleting the addition of Rs. 1,70,04,498/- on the account of unexplained cash credit u/s 68 of IT Act, 1961 without appreciating the fact that no documentary evidence was provided by the assessee to substantiate the legitimacy of the transaction

Deputy Commissioner of Income Tax, Circle-1(1), New Delhi, Delhi vs. Agya Imports Limited, Dlehi

In the result, appeals of Revenue in ITA Nos

ITA 3732/DEL/2024[2014-15]Status: DisposedITAT Delhi03 Sept 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rakesh Sehgal, CAFor Respondent: Shri Anurag S. Daria, Sr. DR

Section 144BSection 147Section 148Section 68Section 69ASection 69C

DCIT CC-1, Ludhiana vs. M/S Oswal Fashion (P) Ltd., G.T.Road (West), Jalandhar Bye Pass, Ludhiana

The appeal stand dismissed

ITA 1020/CHANDI/2019[2011-12]Status: DisposedITAT Chandigarh02 Sept 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1020/Chandi/2019 (िनधा"रणवष" / Assessment Year: 2011-12 Dcit M/S Oswal Fashion (P) Limited बनाम/ Central Circle -1 G.T. Road (West) Ludhiana. Jalandhar Bye Pass, Vs. Ludhiana-141001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-2183-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरAppellant By : Shri Arvind Kumar (Cit) – Ld. Dr ""थ"कीओरसे/Respondent By : Shri Gaurav Sharma (Ca)– Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 25-08-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-09-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2011-12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 05-04-2019 In The Matter Of An Assessment Framed By Ld. Assessing Officer (Ao) U/S 143(3) / 153A Of The Act On 30-03-2015. The Sole Issue That Arises For Our Consideration Is Addition Of Rs.5 Crores As Made By Ld. Ao In The Assessment Order.

For Appellant: Shri Arvind Kumar (CIT) – Ld. DRFor Respondent: Shri Gaurav Sharma (CA)– Ld. AR

Section 143(3)Section 68

identity, genuineness and creditworthiness of these entities and accordingly, added the sale consideration so received by the assessee for Rs.5 Crores as unexplained cash credit u/s 68. 3. The Ld. CIT(A) rendered factual findings that the assessee had duly declared the purchase and sale consideration in the books

Incometax Officer, Ward-2(1)(2), Ahmedabad vs. Chaitanya Prakashbhai Dangi, Ahmedabad

In the result, the appeals of both the assessee and the Revenue are allowed for statistical purposes

ITA 771/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Abhijit, Sr. DRFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 234ASection 234BSection 68Section 69A

given by the assessee to be vague and non-verifiable. Accordingly, the Assessing Officer added the entire amount by treating the same as unexplained cash credit under section 68 of the Act as taxable income of the assessee under section 115BBE of the Act. Further, during the demonetisation period

Chaitanya Prakashchandra Dangi, Ahmedabad vs. The ITO, Ward-2(2)(1), Ahmedabad

In the result, the appeals of both the assessee and the Revenue are allowed for statistical purposes

ITA 570/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Abhijit, Sr. DRFor Respondent: Shri Abhijit, Sr. DR

Section 115BSection 234ASection 234BSection 68Section 69A

Mahalingam Sundara Moorthy, Chennai vs. ITO, Corporate Ward-4(1), Chennai

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

ITA 1682/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Sept 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1682/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Mahalingam Sundara Moorthy, Vs. The Income Tax Officer, 602, Srithi Block, Chitra Avenue, Corporate Ward 4(1), Nungambakkam, Chennai 600 034. Chennai. [Pan:Afypm5382G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri N. Rajakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 26.08.2025 घोषणा की तारीख /Date Of Pronouncement : 02.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: NoneFor Respondent: Shri N. Rajakumar, Addl. CIT

Section 131Section 142(1)Section 143(2)Section 250Section 272A(1)(d)Section 274Section 68

Assessing Officer proceeded to complete the assessment by making disallowances of ₹.17,17,900/-, 23,33,037/- and ₹.23,33,143/- as unexplained cash credit under section 68 of the Act besides disallowance of expenses at ₹.4,56,60,080/- and assessed the income of the assessee

Income Tax Officer-27(3)(1) Mumbai, Vashi vs. Sachin Velji Shah, Mumbai

Appeal of the revenue is dismissed

ITA 1938/MUM/2023[2014-15]Status: DisposedITAT Mumbai02 Sept 2025AY 2014-15

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DRFor Respondent: Shri Prakash Jhunjhunwala, AR

Section 10(38)Section 132(4)Section 133(6)Section 143(3)Section 250Section 68Section 69C

1938/Mum/2023 Sachin Velji Shah 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 purchased ... documents furnished by the assessee. 15. 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 that the purchase of shares made in an earlier year has been accepted by the revenue

Income Tax Officer, Ward-2(2)(3), Ghaziabad vs. Sanjay Thakur, Ghaziabad

ITA 1778/DEL/2025[2009-10]Status: DisposedITAT Delhi02 Sept 2025AY 2009-10

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 1778/Del/2025 : Asstt. Year : 2009-10 Ita No. 1777/Del/2025 : Asstt. Year : 2010-11 Income Tax Officer, Vs Sanjay Thakur, 7Th Floor, 703, Satyam Ansal Ward-2(2)(3), Ghaziabad-201002 Building, Rdc, Ghaziabad-201001 (Appellant) (Respondent) Pan No. Ajrpt9741P Assessee By : None Revenue By : Sh. Mahesh Kumar, Cit-Dr & Sh. Pradumna Kumar Singh, Sr. Dr Date Of Hearing: 02.09.2025 Date Of Pronouncement: 02.09.2025 Order Per Satbeer Singh Godara: These Revenue’S Twin Appeals

For Appellant: NoneFor Respondent: Sh. Mahesh Kumar, CIT-DR &

Section 143(3)Section 148

light of the Revenue’s pleadings that the CIT(A)/NFAC has erred in law and on facts in deleting protective addition of unexplained cash credits amounting to Rs.16,60,36,538/- in assessment order dated 16.12.2016; and, therefore, the same deserves to be revived herein. We note in this