“addition under section 68”

Cash Credits & Unexplained ItemsSection 68Section 681,640 judgments

DCIT, CIRCLE- 19(1), DELHI vs. PASHUPATI ROAD CARRIER PVT. LTD., DELHI

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

ITA 2490/DEL/2025[2017-18]Status: DisposedITAT Delhi20 Mar 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Sudhir Kumardcit, Circle 19(1), Vs. Pashupati Road Carrier Delhi Pvt. Ltd., Room No. 221, 2Nd Floor, Plot No. 70A/47, Ground C.R. Building, Floor, Moti Nagar, I.P. Estate, New Delhi – 110 002 Rama Road Indl. Area, New Delhi – 110 045 (Pan: Aadcp8319H) (Appellant) (Respondent) Assessee By : Sh. Baldev Raj, Ca & Sh. Manish Upneja, Ca Revenue By : Sh. Rajesh Kumar Dhanesta, Sr. Dr. Date Of Hearing : 24.02.2026 Date Of Order : 20.03.2026 O R D E R Per Sudhir Kumar, Jm :

For Appellant: Sh. Baldev Raj, CA & Sh. Manish UpnejaFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 115JSection 133(6)Section 143(2)Section 143(3)Section 40A(3)Section 68

cannot be said that the explanation offered by the appellant in respect of the said amounts has been rejected unreasonably'". 7.9 An addition under Section 68 can be made where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee either

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1392/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

lenders and the loan was repaid in the subsequent year, even the ingredients of creditworthiness and genuineness were deemed satisfied, and therefore, no addition under section 68 could be made. Again, in PCIT v. Ojas Tarmake Pvt. Ltd. (156 taxmann.com 75), it was held that where the unsecured loan ... repaid within the same year through banking channels, the addition under section 68 was wholly unwarranted. The Surat Tribunal in Rajhans Construction Pvt. Ltd. v. ACIT (140 taxmann.com 370) also held that repayment of loan within a short span of time, along with interest, goes to the root of genuineness

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1278/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1277/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

AMBE MARBLE,NEW DELHI vs. ITO WARD 36(1), DELHI, NEW DELHI

In the result, appeal of the assessee is allowed

ITA 4722/DEL/2025[2017-18]Status: DisposedITAT Delhi18 Mar 2026AY 2017-18

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2017-18 Ambe Marble Ito Ward 36(1) Delhi New C/O B-50 Lgf South Vs Delhi Extension Part-Ii, New Delhi Pan No. Abbfa5852G (Appellant) (Respondent)

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 68

cash balance available with the assessee and, hence, there is 13 absolutely no case made out by the revenue for making addition under section 68." 11.In the present case the AO did not point out any defects in the books of account, no discrepancies were found in the stocks, sales

SHREE JADEYA SHANKARLING URBAN CO-OP. CREDIT SOCIETY LIMITED ,HUBBALLI vs. INCOME TAX OFFICER, WARD-2(3), HUBBALLI

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

ITA 2893/BANG/2025[2017-18]Status: DisposedITAT Bangalore17 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Santhosh Magavi, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 269SSection 68

along with other necessary details. However, the AO without going into the explanation furnished along with the relevant details, proceeded to make addition under section 68 of the Act on the ground that the assessee cannot receive the SBN after 8th November 2016. 8.5 We further note that the learned ... Tribunal in the case of Sri Bhageeratha Pattina Sahakara Sangha Niyamitha (supra), wherein in identical facts and circumstances, it was held that the addition under section 68 of the Act cannot be made merely on the ground that the SBN received by the assessee society from its member on account

ACIT-17(1),MUMBAI, MUMBAI vs. SUNIL GIRIDHAR RAHEJA HUF, MUMBAI

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

ITA 7560/MUM/2025[2013-14]Status: DisposedITAT Mumbai16 Mar 2026AY 2013-14

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 133(6)Section 148Section 68

specific material and statements collected by the Investigation Wing indicating that the assessee received accommodation entries, thereby vitiating the finding of deletion of addition under Section 68?" 3. "Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting ... addition under Section 68 by holding that bank-routed transactions are sufficient proof of genuineness, contrary to settled law that mere banking transactions do not establish genuineness or creditworthiness?" 2 I.T.A. No. 7560/Mum/2025 4. The appellant craves the leave to add, substitute, modify, alter, delete or amend

ACIT22(1), MUMBAI vs. UNIQUE BANGLES, MUMBAI

In the result, the appeal of the Revenue is partly allowed

ITA 7427/MUM/2025[2023-24]Status: DisposedITAT Mumbai16 Mar 2026AY 2023-24

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokaracit-22(1) Unique Bangles, 322, Piramal 232/234, Shah & Chambers, Mumbai – Vs. Nahar Industrial 400 013. Estate, S. J. Mar, Dhanraj Mill Compound, Lower Parel, Mumbai-400019 Pan/Gir No. Aadfu8125A (Applicant) (Respondent) Revenue By Shri Vivek Perampurna, Ld. Dr Assessee By Shri Subhash Chhajed & Shri Sunil Vankawala, Ld. Ars Date Of Hearing 09.03.2026 Date Of Pronouncement 16.03.2026

Section 139(1)Section 143(1)Section 143(3)Section 144BSection 36(1)(va)Section 40Section 68

deduct tax at source on various payments such as purchases, professional fees, rent and other expenses – Rs. 23,35,80,090/-. 2. Addition under section 68 on account of unsecured loans treated as unexplained cash credits – Rs. 47,13,589/-. 4 Unique Bangles 3. Disallowance under section ... assessee. In the absence of any adverse material brought on record by the Assessing Officer, the CIT(A) held that the addition under section 68 was not justified and accordingly deleted the addition of Rs. 47,13,589/-. 6 Unique Bangles 9. However, with regard to the disallowance made under

DUGGINNIGARI SUBRAMANIYAM NAIDU,TIRUPATI vs. ACIT., CIRCLE - 1(1), TIRUPATI

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

ITA 1443/HYD/2025[2017-18]Status: DisposedITAT Hyderabad13 Mar 2026AY 2017-18

Bench: the Ld. AO.

Section 133(6)Section 68

cash and re-deposit of the said cash into bank account. In the absence of proper explanation, the A.O. has rightly made addition under Section 68 of the Income-tax Act, 1961. Therefore, he submitted that, the order of the Ld. CIT(A) should be upheld or in the alternative

VANEET AGGARWAL,NEW DELHI vs. ACIT, CIRCLE-14(2), NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 2607/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Section 10(38)Section 143(1)Section 143(2)Section 69ASection 69C

nexemption under section 10(38), Assessing Officer could not question\ngenuneness of those shares or treat them as bogus to make an addition\nunder section 68.\nChief Commissioner of Income-tax (OSD) v. Nilesh Jain (HUF) (2024)\n163 taxmann.com 229 (MP)\n\n4) Where assessee had produced all relevant documentary ... shares of the\ncompany. X matched all the features of the companies which were provided\nbogus long term capital gain and made addition under section 68 of the Act\nby treating long term capital gain as unaccounted Income on the ground that\nthe assessee Invested in shares of company

RAJESH PANANALAL SHAH,VADODARA vs. ASSTT. UNIT,JURIS. AO- DY.CIT, CIRCLE-1(1)(1), VADODARA

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

ITA 2581/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri C Dharani Nath, Sr. DRFor Respondent: Shri C Dharani Nath, Sr. DR

Section 115BSection 142(1)Section 143(2)Section 144Section 250Section 271ASection 68

liabilities reflected in the books of accounts either during the assessment proceedings or during appellate proceedings. Accordingly, Ground No. 1 challenging the addition under section 68 was dismissed. With regard to Ground No. 2 relating to the application of section 115BBE of the Act, the learned CIT(Appeals) held that ... once the addition under section 68 is confirmed, the consequential taxation under section 115BBE follows automatically and therefore the ground was dismissed. Ground No. 3 relating to initiation of penalty under section 271AAC was dismissed as premature since the penalty proceedings had only been initiated and not yet concluded. With

QMIN INDUSTRIES LIMITED,AHMEDABAD vs. THE ITO, WARD-7(2)(1), AHMEDABAD

The appeal of the assessee is allowed for statistical purposes

ITA 1777/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Mahesh Chhajed, ARFor Respondent: Shri C Dharani Nath, Sr. DR

Section 115BSection 143(2)Section 68

assessee challenged the addition on several grounds contending, inter alia, that the Assessing Officer had erred in making the addition under section 68 of the Act without properly appreciating the explanations and documents furnished by the assessee and that the addition had been made merely on suspicion and conjectures

NARAYANLAL BHANAJI PRAJAPATI,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(3), AHMEDABAD

Accordingly, the appeal filed by the assessee is dismissed

ITA 588/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Hardik Vora, ARFor Respondent: Ms. Pallavi, CIT-DR & Shri Rameshwar P

Section 115BSection 132Section 153CSection 68

same formed part of the business income of the assessee. The learned CIT(Appeals) held that the Assessing Officer had made the addition under section 68 of the Act without bringing any material on record to demonstrate that the income declared by the assessee was false or fictitious. The learned

SHRI. SHANTHISAGAR CO OP CREDIT SOCIETY LIMITED,HUBLI vs. INCOME TAX OFFICER, WARD-2(1), HUBLI

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

ITA 2081/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

along with other necessary detail. However, the AO without going into the explanation furnished along with the relevant details, proceeded to make addition under section 68 of the Act on the ground that the assessee cannot receive the SBN after 8th November 2016. 20.6 We further note that the learned ... Shree Jagadguru Mouneshwar Pattin Sahakari Niyamit vs. ITO in ITA No. 1119/Bang/2023, wherein in identical facts and circumstances it was held that the addition under section 68 of the Act cannot be made merely on the ground that the SBN received by the assessee society from its member on account

VIREN VALLABHDAS DHAKAN,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -2(1), RAJKOT, RAJKOT

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

ITA 34/RJT/2025[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

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

For Appellant: Shri D. M. Rindani, Ld. A.RFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 115bSection 143(3)Section 234aSection 250Section 271ASection 271aSection 68

Gopal Heritage (P.) Ltd. (2021) 133 taxmann.com 173, held as: “Where assessee had taken unsecured loans from some persons and Assessing Officer made addition under section 68 on ground that assessee had not been able to prove immediate source of cash-in-hands of party, since all ingredients contemplated under

MURAD KHETANI,HYDERABAD vs. DCIT., CIRCLE-10(1), HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 1376/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 131Section 142(1)Section 68

could not have made additions during the year under consideration.” and under these circumstances, the A.O. was not justified in making the addition under Section 68 of the Act. Since the addition made by the A.O. towards suspense (Vistas account difference) for Rs. 10,60,000/- and suspense account

EAST DELHI LEASING P.LTD,NEW DELHI vs. ITO, WARD-8(1), NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11

Section 142(1)Section 147Section 148

finance business inherently involves fund movement and that the AO lacked independent application of mind. The AO rejected the objections and made an addition under Section 68 for share application money.", "held": "The Tribunal held that the AO's belief of escapement of income was based on a borrowed satisfaction

JCIT, (OSD), CIRCLE 1(1), RAIPUR, RAIPUR vs. PLATINUM WORLD HOSPITALITY PRIVATE LIMITED, RAIPUR, RAIPUR

In the result appeal filed by the appellant is allowed

ITA 130/RPR/2026[2014-15]Status: DisposedITAT Raipur10 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.130/Rpr/2026 "नधा"रण वष" /Assessment Year : 2014-15 The Joint Commissioner Of Income Tax (Osd), Circle-1(1), Raipur (C.G.)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 68

satisfactorily established the identity, creditworthiness and genuineness of the share capital/share premium received from M/s Aravali Highrise Pvt. Ltd. so as to avoid addition under Section 68 of the Act? 5. Discussion and Findings 5.1 Legal Requirements under Section 68 Section 68 requires an appellant to satisfactorily explain the nature ... Orissa Corporation (159 ITR 78) held that where the appellant provides complete details and the Assessing Officer fails to pursue further enquiry, the addition under section 68 cannot be justified. In the present case, the Assessing Officer's failure to conduct proper enquiry amounts to a violation of principles

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 5(3), MUMBAI, MUMBAI vs. SANGHVI DHANRUPJI DEVAJI & CO., MUMBAI

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

ITA 6015/MUM/2025[AAQFS6338H]Status: DisposedITAT Mumbai10 Mar 2026

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Prusethdeputy Commissioner Of Vs. Sanghvi Dhanrupji Income Tax Central Circle Devaji & Co. 5(3), Mumbai 33, Mumba Devi Road, Room No. 426, 4Th Floor, Dagina Bazar, Kautilya Bhavan, Mumbai- 400002 Mumbai- 400051 Pan/Gir No. Aaqfs6338H (Applicant) (Respondent) Assessee By Shri M B Sanghvi Revenue By Ms. Kavitha Kaushik,Sr.Dr. Date Of Hearing 21.01.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Revenue Challenging The Impugned Order Dated 23.12.2024 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2014-15. The Revenue Has Raised The Following Grounds Of Appeal: 1. Ground I - Whether On The Facts & The Circumstances Of The Case & In Law, The Cit(A) Erred In Deleting/Allowing Relief In Respect Of The Addition Of Rs.

Section 250Section 40A(3)(a)Section 68

decision of Hon'ble ITAT Vishakhapatnam in the case of ACIT vs. HeerapannaJewellers, ITA No. 253/Viz/2020 wherein ITAT held that where AO made addition under section 68 on account of huge cash amount deposited by assessee-jeweler inits bank account post demonetization, since assessee had explained source of said cash ... case of ACIT vs. Heerapanna Jewellers, ITA No. 253/Viz/2020 wherein ITAT held that 18 Sanghvi Dhanrupji Devaji& Co. where AO made addition under section 68 on account of huge cash amount deposited by assessee-jeweler in its bank account post demonetization, since assessee had explained source of said cash deposits

SAWASTIKA PRINTING & PACKAGING,KALA MAB vs. ASSESSING OFFICER, NAHAN

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

ITA 1222/CHANDI/2025[2017-2018]Status: DisposedITAT Chandigarh09 Mar 2026AY 2017-2018

Bench: the Hon'ble CIT(A)(NFAC) that assessee is having business turnover of Rs 16,77,30,943/-. While upholding the additions of Rs 20,81,000/- the Hon'ble CIT(A) (NFAC) has observed in last para of his order as under:-

For Appellant: Shri Yad Ram Saini, Advocate and Shri Neeraj Jain, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR (Virtual Mode)

Section 132Section 139(4)Section 144Section 147

could not be held to be invalid. Accordingly, the grounds challenging jurisdiction and legality of assessment were dismissed. 4.1 On merits of the addition under section 68, the Ld. CIT(A) observed that the assessee had admittedly advanced a sum of Rs.82,74,000/- to M/s Shree Krishna Packaging during

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