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“addition under section 68”

Cash Credits & Unexplained ItemsSection 68Section 681,640 judgments

The decision most relied on for addition under section 68 is CIT v. Durga Prasad More (82 ITR 540), cited in 1,579 judgments on BharatTax.

Leading authorities on addition under section 68

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

CIT v. Lovely Exports (P) Ltd.
216 CTR 195 · 2008 · Supreme Court
854
citing judgments

If an assessee company receives share application money from alleged bogus shareholders and provides their details to the Assessing Officer, no addition can be made under Section 68 in the company's hands; the Department must proceed against the shareholders by reopening their individual assessments.

CIT v. Bholanath Poly Fab. Pvt. Ltd.
355 ITR 290 · 2013 · High Court
712
citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

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.

Umacharan Shaw & Bros. v. CIT
37 ITR 271 · 1959 · Supreme Court
567
citing judgments

An income tax assessment or addition cannot be sustained solely on the basis of suspicion, surmises, or conjectures, as strong suspicion does not amount to proof. The revenue authorities must rely on concrete evidence and material to frame an assessment.

Roshan Di Hatti v. CIT
107 ITR 938 · 1977 · Supreme Court
477
citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

Judgments citing addition under section 68

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Circle Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1312/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

that, three issues were involved in the appeal of the assessee i.e. (a) Addition under section 69A of the Act (Rs.70 lakhs), (b) Addition under section 68 of the Act (Rs.17,31,763/-) and Addition on account of LTCG (Rs.68,21,680/-). As far as the addition under section ... submitted that the cash of Rs.70 lakhs are properly explainable and the addition is liable to be deleted. 7. With regard to the addition under section 68 of the Act (Rs.17,31,763/-), the Ld. AR submitted that, the Ld. AO has made the addition on account of highest peak

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1311/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

that, three issues were involved in the appeal of the assessee i.e. (a) Addition under section 69A of the Act (Rs.70 lakhs), (b) Addition under section 68 of the Act (Rs.17,31,763/-) and Addition on account of LTCG (Rs.68,21,680/-). As far as the addition under section ... submitted that the cash of Rs.70 lakhs are properly explainable and the addition is liable to be deleted. 7. With regard to the addition under section 68 of the Act (Rs.17,31,763/-), the Ld. AR submitted that, the Ld. AO has made the addition on account of highest peak

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1310/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

that, three issues were involved in the appeal of the assessee i.e. (a) Addition under section 69A of the Act (Rs.70 lakhs), (b) Addition under section 68 of the Act (Rs.17,31,763/-) and Addition on account of LTCG (Rs.68,21,680/-). As far as the addition under section ... submitted that the cash of Rs.70 lakhs are properly explainable and the addition is liable to be deleted. 7. With regard to the addition under section 68 of the Act (Rs.17,31,763/-), the Ld. AR submitted that, the Ld. AO has made the addition on account of highest peak

Papi Reddy Ankannagari, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 1309/HYD/2024[2019-20]Status: DisposedITAT Hyderabad12 Sept 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1309 To 1312/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2019-20) Shri Papi Reddy Ankannagari, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan: Adopa4689A Central Circle 3(3), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Shri Gurpreet Singh, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 02/09/2025 घोर्णध की तधरीख/Pronouncement: 12/09/2025 आदेश/Order Per Bench : These Appeals Are Filed By Shri Papi Reddy Ankannagari (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Hyderabad-11 (“Ld. Cit(A)”), Dated 28.11.2024, 02.12.2024, 29.11.2024 & 28.11.2024 Respectively For The A.Y. 2019-20. Since These Appeals Are Related To The Same Assessee & For The Same A.Y. 2019-20, They

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Gurpreet Singh, SR-DR
Section 132ASection 143(2)Section 147Section 148Section 68Section 69A

that, three issues were involved in the appeal of the assessee i.e. (a) Addition under section 69A of the Act (Rs.70 lakhs), (b) Addition under section 68 of the Act (Rs.17,31,763/-) and Addition on account of LTCG (Rs.68,21,680/-). As far as the addition under section ... submitted that the cash of Rs.70 lakhs are properly explainable and the addition is liable to be deleted. 7. With regard to the addition under section 68 of the Act (Rs.17,31,763/-), the Ld. AR submitted that, the Ld. AO has made the addition on account of highest peak

Delhi vs. Sma Goyal Jewellers Pvt Ltd, Delhi

In the result, appeal filed by the assessee is allowed

ITA 5583/DEL/2024[2017-18]Status: DisposedITAT Delhi12 Sept 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalacit, Sma Goyal Jewellers Pvt. Ltd., Central Circle-29, I-45, Arya Samaj Road, New Delhi. Vs. Uttam Nagar, West Delhi-110059. Pan:Aajcs4890G (Appellant) (Respondent) Assessee By Shri Sanjeev Batra, Adv. & Shri Kailash Khemani, Ca Department By Shri Narpat Singh, Sr. Dr Date Of Hearing 24.06.2025 Date Of Pronouncement 12.09.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Revenue Against The Order Of Learned Commissioner Of Income Tax (Appeals)-30 In Appeal No. 08/10437/2019-20 Dated 25.09.2024 For Assessment Year 2017-18 Arising Out Of Assessment Order Passed U/S 143(3) Of The Income Tax Act, 1961 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Company & E-Filed Its Return Of Income On 23.10.2017 Declaring Total Income At Rs.4,35,580/-. The Case Of The Assessee Was Selected For Complete Scrutiny. Assessee Has Made Cash Deposit Of Rs.98,00,000/- In Specified Bank Notes (Sbn) In Kotak Mahindra Bank Account. During The Course Of The Assessment Proceedings, Details Have Been Asked For Time To Time & The Assessing Officer Has Issued Summons To The Parties To Whom Sales Stated To Have Been Made In Cash. Since, Most Of The Parties Has Not Responded To The Notices Issued By The Assessing Officer, He Was Of The Opinion That Cash Deposited During

Section 133(6)Section 143(3)Section 68Section 69A

made out of cash balance available with the assessee and, hence, there is absolutely no case made out by the revenue for making addition under section 68." Further, in the case of Fine Gujaranwala Jewellers Vs. ITO (ITA No. 1540/Del/2022 dated 27.03.2023, wherein it was held as under

Bharat Kumar, Chennai vs. ITO, Ncw-4(5), Chennai

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

ITA 784/CHNY/2025[2016-17]Status: DisposedITAT Chennai11 Sept 2025AY 2016-17

Bench: Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.784/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Bharat Kumar, Vs. The Income Tax Officer, No. 152, 10Th Street, Deber Nagar, Non Corporate Ward 4(5), Vyasarpadi 600 039,Chennai. Chennai 600 006. [Pan:Bfhpb6487D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R.S. Hithesh, Advocate For Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.09.2025 घोषणा की तारीख /Date Of Pronouncement : 11.09.2025 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.02.2025 Passed By The Addl/Jcit(A)-1, Bengaluru For The Assessment Year 2016-17. 2. The Ld. Ar Shri R.S. Hithesh, Advocate Placed On Record Memo Of Additional Ground & Requested To Take Up The Said Additional Ground As Preliminary Issue. After Hearing Both The Parties, I Am Inclined To Treat The Additional Ground As Preliminary Issue.

For Appellant: Shri R.S. Hithesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Ms. V. Aswathy, JCIT
Section 133(6)Section 68Section 69

circumstances of the case. She argued that the ld. CIT(A) has ample power in directing the Assessing Officer to treat the addition under section 68 of the Act. She submits, by referring to the case law as relied upon by the ld. AR, that in the said case