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cash credit addition

Cash Credits & Unexplained ItemsSection 68Section 6867 judgments

DY. COMMISSIONER OF INCOME TAX, NOIDA vs. M/S RUDRA BUILDWELL HOMES PVT. LTD, DELHI

ITA 602/DEL/2025[2016]Status: DisposedITAT Delhi29 Aug 2025

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2016-17 Vs. M/S. Rudra Buildwell Homes Dcit, Central Circle-I, Noida Pvt. Ltd., 53, Okhla Phase, Delhi Pan: Aafcr6959P (Appellant) (Respondent) With C.O. No.106/Del/2025 [Arising Out Of Ita No.602/Del/2025] Assessment Year: 2016-17 M/S. Rudra Buildwell Vs. Dcit, Central Circle-I, Homes Pvt. Ltd., Noida A-66, Sector-63, Noida Pan: Aafcr6959P (Appellant) (Respondent) Assessee By Sh. Rohit Kapoor, Adv. Sh. Veersen Agarwal, Itp Department By Sh. Rajesh Chandra, Cit(Dr) Date Of Hearing 12.08.2025 Date Of Pronouncement 29.08.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.602/Del/2025 & Assessee’S Cross Objection C.O. No. 106/Del/2025 For Assessment Year 2016-

Section 143(3)Section 148Section 148ASection 151Section 151(1)Section 151(2)

rival submissions. We are of the considered view that the learned CIT(A)’s foregoing detailed findings deleting the impugned section 68 unexplained cash credit addition warrant no interference on our part. Suffice to say, the assessee had admittedly received a sum of Rs.12.08 crores on 28.03.2016 coming from ... high court’s decision in Tax Appeal No.1180 of 2018 PCIT Vs. Gyscoal Alloys Ltd., dated 1st October, 2018 that section 68 unexplained cash credits addition in an instance involving group entities and directors etc. assessed in the same jurisdiction who satisfy the corresponding three limbs of identity, genuineness

DCIT, DELHI vs. SHALIMAR CORP. LIMITED, MUMBAI

ITA 2502/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

SHALIMAR CORP LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-30, , NEW DELHI

ITA 2360/DEL/2023[2011-12]Status: DisposedITAT Delhi31 Jul 2025AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

DCIT, CENTRAL CIRCLE-30, NEW DELHI vs. SHALIMAR CORP. LTD., MUMBAI

ITA 2854/DEL/2022[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

DCIT, CENTRAL CIRCLE-30, NEW DELHI vs. SHALIMAR CORP. LTD., MUMBAI

ITA 2853/DEL/2022[2013-14]Status: DisposedITAT Delhi31 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

SHALIMAR CORP LTD,LUCKNOW vs. DCIT, CENTRAL CIRCLE-30, NEW DELHI

ITA 2768/DEL/2022[2016-17]Status: DisposedITAT Delhi31 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

SHALIMAR CORP LTD.,LUCKNOW vs. DCIT, CENTRAL CIRCLE-30, NEW DELHI

ITA 2767/DEL/2022[2015-16]Status: DisposedITAT Delhi31 Jul 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

SHALIMAR CORP LTD.,LUCKNOW vs. DCIT, CENTRAL CIRCLE-30, NEW DELHI

ITA 2766/DEL/2022[2014-15]Status: DisposedITAT Delhi31 Jul 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

SHALIMAR CORP LTD.,LUCKNOW vs. DCIT,CENTRAL CIRCLE-30, NEW DELHI

ITA 2765/DEL/2022[2013-14]Status: DisposedITAT Delhi31 Jul 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

SHALIMAR CORP LTD.,LUCKNOW vs. DCIT CENTER CIRCLE-30, DELHI

ITA 2764/DEL/2022[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2011-12 Vs. Dcit, M/S. Shalimar Corp Ltd., A 2/3, Safdarjung Enclave, Central Circle-30, New Delhi New Delhi Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2764 To 2768/Del/2022 Assessment Years: 2012-13 To 2016-17 Vs. Dcit, M/S. Shalimar Corp Ltd., 11Th Floor, Shalimar Titanium, Central Circle-30, Vibhuti Khand, Gomti Nagar, New Delhi Lucknow Pan: Aadcs9234L (Appellant) (Respondent) With Ita Nos.2502/Del/2023; 2853 & 2854/Del/2022 Assessment Years: 2011-12, 2013-14 & 2015-16 Vs. M/S. Shalimar Corp Ltd., Dcit, Central Circle-30, 308, Tulsiani Chamber, New Delhi Nariman Point, Mumbai Pan: Aadcs9234L (Appellant) (Respondent) Assessee By Sh. Subhash Agarwal, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132(4)Section 139(1)Section 142Section 153ASection 153DSection 250Section 285

assessee preferred its appeal before the learned CIT(A) which stands partly accepted to the extent that the above section 68 unexplained cash credit addition of Rs.2,90,00,000/- has been deleted and all other assessment findings have been confirmed. It is in this factual backdrop that both ... reverse both the learned lower authorities’ action hereinabove in entirety as against the department’s sole substantive grievance seeking to revive the unexplained cash credit addition of Rs.2,90,00,000/-; respectively. 6. We have given our thoughtful consideration to the assessee’s and the department’s vehement submissions reiterating

DCIT, CR BUILDING vs. GULSHAN POLYOLS LIMITED, LAXMI NAGAR

Appeal is dismissed

ITA 5549/DEL/2024[2015-16]Status: DisposedITAT Delhi28 May 2025AY 2015-16

Bench: Shri Satbeer Singh Godara\Nand\Nshri Manish Agarwal\N\Nita No.5549/Del/2024\N Assessment Year: 2015-16\Nvs. M/S. Gulshan Polyols Limited,\Ng-81, Preet Vihar, Anand Vihar\Ns.O. Laxmi Nagar, East Delhi\Npan: Aabcg3954F\N(Appellant)\N(Respondent)\Nwith\Nc.O. No. 46/Del/2025\N[Arising Out Ita No.5549/Del/2024]\N Assessment Year: 2015-16\Nm/S. Gulshan Polyols Vs. Dcit (Osd),\Nlimited,\Nrange-10,\Ng-81, Preet Vihar, Anand New Delhi\Nvihar S.O. Laxmi Nagar,\Neast Delhi\Npan: Aabcg3954F\N(Appellant)\N(Respondent)\Nassessee By\Nsh. Mohd. Shahid, Ca\Ndepartment By\Nsh. Rajesh Kumar Dhanesta, Sr. Dr\Ndate Of Hearing\N28.05.2025\Ndate Of Pronouncement\N28.05.2025\Norder\Nper Satbeer Singh Godara, Jm\Nthis Revenue'S Appeal (Ita No.5549/Del/2024) And\Nassessee'S Cross Objection (C.O. No. 46/Del/2025) For Assessment\Nyear 2015-16, Arises Against The Commissioner Of Income Tax\N(Appeals)/National Faceless Appeal Centre [In Short, The\N\"Cit(A)/Nfac"], Delhi'S Din & Order No.\Nitba/Nfac/S/250/2024-25/1068966016(1), Dated 23.09.2024\Ninvolving Proceedings Under Section 147 R.W.S.144 Of The Income-\Ntax Act, 1961 (Hereinafter Referred To As 'The Act').\N2. Heard Both The Parties. Case Files Perused.\N3. Coming To The Revenue'S Sole Substantive Ground Seeking To\Nrevive Section 68 Unexplained Cash Credit Addition Of Rs.\N1,17,35,487/- Made By The Assessing Officer In His Assessment\Nframed On 18.05.2023, We Note That The Cit(A) Has Reversed The\Nsame As Under:\N“6.

Section 147Section 68

Heard both the parties. Case files perused.\n3. Coming to the Revenue's sole substantive ground seeking to\nrevive section 68 unexplained cash credit addition of Rs.\n1,17,35,487/- made by the Assessing Officer in his assessment\nframed on 18.05.2023, we note that the CIT(A) has reversed

INCOME TAX OFFICER, DELHI vs. FLORIDA ELECTRICAL INDUSTRIES LTD., DELHI

Appeal is treated as allowed

ITA 1740/DEL/2024[2018-19]Status: DisposedITAT Delhi23 May 2025AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 1740/Del/2024 : Asstt. Year : 2018-19 Income Tax Officer, Vs Florida Electrical Industries Ltd., Ward-9(1), B-147, Mayapuri, Industrial Area- New Delhi-110002 1, New Delhi-110064 (Appellant) (Respondent) Pan No. Aaacf0359C Assessee By : Sh. Prempal Sharma, Ca Revenue By : Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing: 23.04.2025 Date Of Pronouncement: 23.05.2025 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2018-19, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/1060913260(1) Dated 14.02.2024, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Prempal Sharma, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR
Section 133(6)Section 143(3)Section 68

Both the learned representatives next invites our attention to the CIT(A)/NFAC’s lower appellate discussion deleting the impugned section 68 unexplained cash credit addition of Rs.5,49,49,095/- made by the Assessing Officer in his regular assessment dated 14.04.202, reading as under: “5. I have considered ... refers to amounts credited in books of account, remained unexplained then the same needs to be added. Recorded sales are not unexplained cash credits. Addition if any can be made only when the sales shown by assessee are less than the purchases shown by the buyer. E.g. : If the sales

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