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“addition u/s 68”

Cash Credits & Unexplained ItemsSection 68Section 682,598 judgments

The decision most relied on for addition u/s 68 is CIT v. Lovely Exports (P) Ltd. (216 CTR 195), cited in 854 judgments on BharatTax.

Leading authorities on addition u/s 68

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. Divine Leasing & Finance Ltd.
299 ITR 268 · 2008 · High Court
426
citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Devi Prasad Vishwanath Prasad
72 ITR 194 · 1969 · Supreme Court
272
citing judgments

If there is an unexplained cash credit, the Assessing Officer can treat it as the assessee's income, even when the income is finalized on an estimation basis, without proving its specific source. The onus then shifts to the assessee to prove that the income represented by the cash credit has already been taxed.

CIT v. Dwarkadhish Investment (P) Ltd.
330 ITR 298 · 2011 · High Court
218
citing judgments

An assessee cannot be asked to explain the source of the source for cash credits, particularly share capital or share application money, once they have discharged the initial onus regarding the identity, genuineness of the transaction, and creditworthiness of the immediate investor.

1) CIT v. Sahibganj Electric Cables Pvt. Ltd. (
151 ITR 150 · 1985 · High Court
79
citing judgments

The assessee's burden under Section 68 to prove cash credits is discharged by establishing the identity of the creditor and the genuineness of the transaction; the assessee is not required to prove the creditor's source of funds or creditworthiness, as the department can use Section 131 for further investigation.

Jatia Investment Co. v. CIT
206 ITR 718 · 1994 · High Court
77
citing judgments

An addition under Section 68 for unexplained cash credits cannot be made when there is no actual cash credit or flow of funds, such as in cases of share swaps or notional credits.

Hastimal v. CIT
49 ITR 273 · 1963 · High Court
57
citing judgments

An assessee's duty regarding the creditworthiness of a creditor is limited to the transactions between them, and they are not required to investigate the ultimate source of the creditor's funds. If the genuineness of the transaction and the creditworthiness are established, no addition under Section 68 is permissible.

CIT v. Prameshwar Bohra
301 ITR 404 · 2008 · High Court
47
citing judgments

An amount already credited in the books of account in an earlier assessment year cannot be added again as an unexplained cash credit under Section 68 of the Income-tax Act in a subsequent assessment year.

Judgments citing addition u/s 68

Manish Jain, Delhi vs. Income Tax Officer, Delhi

The appeal of the assessee is allowed partly

ITA 3203/DEL/2024[2017-18]Status: DisposedITAT Delhi20 May 2026AY 2017-18

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Sanjay Kumar, CA; &For Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 143(3)Section 68

under section 68. 2. That the addition made being the cash receipts represent the sales were already been offered to taxation, therefore, making addition u/s 68 of the Act has resulted in double taxation on the assessee. 3. That the Ld. A.O. grossly erred in making addition

Lal Chand Choudhary, Jaisalmer vs. ACIT/DCIT Circle, Barmer

In the result, appeal of the assessee is allowed

ITA 840/JODH/2025[2017-18]Status: DisposedITAT Jodhpur09 Apr 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blelal Chand Choudhary Acit/ Dcit, Circle, S-8, Transport Nagar, Barmer Jaisalmer - 345001 Pan No. Aaopc 6671 K Assessee By Shri Rajendra Jain, Advocate & Smt. Raksha Birla, Ca (Physical) Revenue By Shri Lalit Kumar Bishnoi, Addl. Cit-Dr (Virtual) Date Of Hearing 29.01.2026. Date Of Pronouncement 09.04.2026. Order Dr. Mitha Lal Meena, A.M.:

Section 143(2)Section 44ASection 68Section 69A

Likewise, he observes that VAT acceptance of derive over does not preclude scrutiny or addition under the Income Tax Act while sustaining the addition u/s 68 and 69 of the Act. 11. The ld. Counsel for the assessee had explained with evidence the cash received on sale of tractors

Rameshkumar Karsanbhai Patel, Surat vs. ITO, Ward 2(3)(5), Surat

Accordingly the estimated addition made of Rs.35,166/-[0.5% of 70,33,182/-] by the AC invoking provision of section 69C of the I.T Act stand deleted. Thus this ground is allowed

ITA 669/SRT/2025[2015-16]Status: DisposedITAT Surat09 Apr 2026AY 2015-16

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

Section 10(38)Section 115Section 115BSection 250Section 68Section 69C

evidence as bogus or fabricated. 2. Ld. CIT(A), NFAC, Delhi has erred in law and on fact to upheld AO's addition u/s 68 of the act for Rs. 70,33,182/- on factually incorrect assumption that the appellant has credited her capital account by share sale receipts ... entries. 5. Aggrieved by the order of the Assessing Officer, the assessee filed an appeal before the Ld. CIT(A) who confirmed the addition u/s 68 of the Act but deleted the addition made u/s 69C of Rs. 35,166/- of the Act by observing as under:- “I have considered

DCIT, Central Circle-30, New Delhi vs. Shalimar Corp. Ltd, Mumbai

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

ITA 3068/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Subhash Aggarwal, AdvFor Respondent: Shri Mahesh Rajani, CIT-DR
Section 143(3)Section 153ASection 68

adoption of GP rate at the rate of 37.72% by the authorities below. 6. In so far as the additions related to addition u/s 68 of the Act on account of share Capital and loans which were confirmed by the ld Page 3 of 19 ITA No. 3068/DEL/2022 Shalimar Corp ... relief of Rs. 1,56,41,000/- being cash withdrawals from bank accounts of the assessee. Ground 3 of the assessee relates to addition u/s 68 of Rs 3,34,11,525/- received as loan from Saket Niketan P Ltd. Page 12 of 19 ITA No. 3068/DEL/2022 Shalimar Corp

Shalimar Corp Ltd, Lucknow vs. DCIT, Central Circle-30, New Delhi

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

ITA 2769/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Subhash Aggarwal, AdvFor Respondent: Shri Mahesh Rajani, CIT-DR
Section 143(3)Section 153ASection 68

adoption of GP rate at the rate of 37.72% by the authorities below. 6. In so far as the additions related to addition u/s 68 of the Act on account of share Capital and loans which were confirmed by the ld Page 3 of 19 ITA No. 3068/DEL/2022 Shalimar Corp ... relief of Rs. 1,56,41,000/- being cash withdrawals from bank accounts of the assessee. Ground 3 of the assessee relates to addition u/s 68 of Rs 3,34,11,525/- received as loan from Saket Niketan P Ltd. Page 12 of 19 ITA No. 3068/DEL/2022 Shalimar Corp

Gyan Prakash Gupta, New Delhi vs. ITO Ward-10(4), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 6271/DEL/2019[2015-16]Status: DisposedITAT Delhi09 Apr 2026AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarlate Gyan Prakash Gupta Vs. Ito Through Legal Heir Raj Ward 10(4) Kumari Gupta New Delhi Plot No.6 & 7, Defence Enclave, Laxmi Nagar, East Delhi 110092 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adupg 2697 N Appellant .. Respondent

For Appellant: Sh. Ajit Gandhi, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 10Section 10(38)Section 143(2)Section 143(3)Section 250Section 68

Gyan Prakash Gupta (AY 2015-16) 4.1 Ld. AR has submitted that the Revenue authorities have made the addition u/s 68 of the Act invoking the principle of human probabilities and suspicious surrounding only and on the basis of weak financials of these companies, SEBI Proceedings, Investigation wing, Kolkata, report ... contention that wrong section is invoked to make the addition it was submitted by the Id. AR that A.O. has made the addition u/s 68 in the Assessment Order, whereas in the remand proceedings, he specifically asked CIT(A) to consider the additions u/s 69A. However, CIT (A), in Para

Rajeshkumar Kantilal Pujara, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(4), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1957/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Mar 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

Section 115BSection 143(3)Section 250Section 68

have been held that there is no outstanding sundry Creditor, nor is there any transaction during the current assessment year to justify the addition u/s 68 of the Act, and the entire addition ought to have been deleted as prayed for. (3) In the alternate, and without prejudice, on facts

Hameeclass Builders, Mumbai vs. Income Tax Officer, Parel

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

ITA 6859/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Vishwas MehendaleFor Respondent: Shri Hemanshu Joshi, SR. DR
Section 142(1)Section 148Section 250

Audit. 4. On the Facts and Circumstances of the case and in law, learned lower authorities have erred in making addition u/s 68 of the Act, in respect of the Capital Introduced in the Firm by their partners. 5. On the Facts and Circumstances of the case

Pradeep Sharda, Dehradun vs. ACIT, Dehradun

In the result, the appeal of the assessee is allowed

ITA 223/DDN/2025[2017-18]Status: DisposedITAT Dehradun25 Mar 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2017-18] Pradeep Sharda Vs Acit 7, Inder Road, Dehradun Circle-1(2)(1) Uttarakhand -248001 Dehradun Pan-Adwps5692K Uttarakhand Appellant Respondent Appellant By Shri Anil Jain, Adv. Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 12.03.2026 Date Of Pronouncement 25.03.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 24.09.2025 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-1, Nashik [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10344/2019-20 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 01.11.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Is A Practicing Doctor & E-Filed His Return Of Income, Declaring Total Income Of Inr 2,16,70,906/- On 30.10.2017. The Assessment Was Completed U/S 143(3) Of The Act By Making Additions Of Inr 15,84,870/- Comprising Of The Disallowance U/S 40(A)(Ia) Of The Act Of Inr 5,05,195/- & Treating The Agricultural Income Of Inr 6,25,000/- As Unexplained Money U/S 69A Of The Act & Of Inr 4,54,675/- As The Addition U/S 68 Of The Act On Account Of Cash Credit.

Section 143(3)Section 250Section 40Section 68Section 69A

agricultural income of INR 6,25,000/- as unexplained money u/s 69A of the Act and of INR 4,54,675/- as the addition u/s 68 of the Act on account of cash credit. 3. In first appeal, Ld. CIT(A) has deleted the addition

Narayan Barter Private Limited, Kolkata vs. Income Tax Officer, Ward-6(1), Kolkata

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

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

Grounds 1, 3, 7, and 8 are dismissed.” 3.1 The Ld. CIT(A) thus confirmed the reopening of the assessment. As regards the addition u/s 68 of the Act, the assessee had contended that this was not a case of fresh credits and the addition made on account of unexplained

Neeraj, Faridabad vs. Pr, CIT, Faridabad

In the result, appeal filed by the assessee stands allowed

ITA 939/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Mar 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 144Section 144BSection 147Section 148Section 263Section 44ASection 68Section 69A

action of the Pr.CIT, who ignored the basic fact that in the absence of books of accounts in Sec.44AD case no addition u/s 68 of the Act could be made. Even otherwise the order of the Ld. AO impugned by the Pr.CIT is blemishless and deserves to be / affirmed

Neeraj, Faridabad vs. ITO, Ward-2(1), Faridabad

In the result, appeal filed by the assessee stands allowed

ITA 938/DEL/2025[2012-13]Status: DisposedITAT Delhi20 Mar 2026AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 144Section 144BSection 147Section 148Section 263Section 44ASection 68Section 69A

action of the Pr.CIT, who ignored the basic fact that in the absence of books of accounts in Sec.44AD case no addition u/s 68 of the Act could be made. Even otherwise the order of the Ld. AO impugned by the Pr.CIT is blemishless and deserves to be / affirmed

Kuber Finance (I) Ltd, New Delhi vs. ACIT Circle-14(2), New Delhi

In the result, the appeal of the assessee is dismissed

ITA 1877/DEL/2020[1997-98]Status: DisposedITAT Delhi20 Mar 2026AY 1997-98

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1997-98

Section 143(3)Section 250Section 68

file of the AO directing him to verify the year of receipt from the bank statement. The AO, in consequence, reiterated the said addition u/s 68 in the instant year i.e., AY 1997-98. 7. We find that the such a claim of receipt of share application money ... assessee in AY 1997-98. 9. The issue left now is what is the year of receipt of the funds for addition u/s 68. We are of the considered view that the law mandates the invocation of provisions of section 68 of the Act on sum in the year

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

also filed cross-appeals before the Tribunal for certain assessment years, challenging the additions sustained/confirmed by the Ld. CIT(A). ISSUE NO. 1 – ADDITION U/S 68 ON ACCOUNT OF UNSECURED LOANS (ALL YEARS BY REVENUE AND FOR AYs 2018-19 to 2020-21 BY ASSESSEE) 8. The Assessing Officer made ... addition u/s 68 of the Act holding that the assessee failed to establish the creditworthiness of the lenders and that the loans were part of accommodation entry arrangement unearthed during search. The Ld. CIT(A) examined the details lender-wise and recorded that the assessee had furnished confirmations, PAN, copies

ACIT, Central Circle-2, 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

also filed cross-appeals before the Tribunal for certain assessment years, challenging the additions sustained/confirmed by the Ld. CIT(A). ISSUE NO. 1 – ADDITION U/S 68 ON ACCOUNT OF UNSECURED LOANS (ALL YEARS BY REVENUE AND FOR AYs 2018-19 to 2020-21 BY ASSESSEE) 8. The Assessing Officer made ... addition u/s 68 of the Act holding that the assessee failed to establish the creditworthiness of the lenders and that the loans were part of accommodation entry arrangement unearthed during search. The Ld. CIT(A) examined the details lender-wise and recorded that the assessee had furnished confirmations, PAN, copies

ACIT, Central Circle-2, 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

also filed cross-appeals before the Tribunal for certain assessment years, challenging the additions sustained/confirmed by the Ld. CIT(A). ISSUE NO. 1 – ADDITION U/S 68 ON ACCOUNT OF UNSECURED LOANS (ALL YEARS BY REVENUE AND FOR AYs 2018-19 to 2020-21 BY ASSESSEE) 8. The Assessing Officer made ... addition u/s 68 of the Act holding that the assessee failed to establish the creditworthiness of the lenders and that the loans were part of accommodation entry arrangement unearthed during search. The Ld. CIT(A) examined the details lender-wise and recorded that the assessee had furnished confirmations, PAN, copies

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

accepted SBNs which is illegal tender and hence, the cash credits in its books are unexplained. Hence, the AO has rightfully made the addition u/s 68 of the Act. Hence, the ground of the assessee is dismissed. 5. Being aggrieved by the order of the learned CIT(A), the assessee ... books of account, it was held that when Assessee already admitted sale proceeds as revenue receipts . Therefore there is no case of addition u/s 68" We also find support from the decisions of coordinate benches of the Tribunal in Sri Bhageeratha Pattina Sahakara Sangha Niyamitha (ITA No.646/Bang/2021), where

Income Tax Officer Ward 6 (1), Mohali vs. Skycity Builders and Promoters Private Limited, Khrar Punjab

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1217/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

borrowings as introduced by Finance Act, 2022 would apply only from AY 2023-24 and subsequent assessment years. The bench further held that addition u/s 68 could not be made on preponderance of probability and there has to be some evidence and substance in the contention put forward ... decision of Jurisdictional Punjab & Haryana High Court in the case of CIT Vs Karaj Singh (15 Taxmann.com 70). The Agra Tribunal held that addition u/s 68 could not be made on preponderance of probability and there has to be some evidence to establish the fact of unexplained cash credit

Skycity Builders and Promoters Private Limited, Kharar, Rupnagar vs. DCIT Ward 6(1), Chandigarh Jao ITO 6(1) Mohali, Chandigarh

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1066/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

borrowings as introduced by Finance Act, 2022 would apply only from AY 2023-24 and subsequent assessment years. The bench further held that addition u/s 68 could not be made on preponderance of probability and there has to be some evidence and substance in the contention put forward ... decision of Jurisdictional Punjab & Haryana High Court in the case of CIT Vs Karaj Singh (15 Taxmann.com 70). The Agra Tribunal held that addition u/s 68 could not be made on preponderance of probability and there has to be some evidence to establish the fact of unexplained cash credit

DCIT, Circle 2(1), Trichy Stationed at Thanjavur, Thanjavur vs. Sri Bhuvanesvari Thangamaligai, Pudukkottai

In the result, appeal filed by the Revenue is dismissed

ITA 2915/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Respondent: Ms.R. Anitha, Addl.CIT
Section 133ASection 68

from 08.11.2016. Hence according to Ld CIT(A) the AO impliedly accepted the nature and source of SBNs as sales receipt, and hence addition u/s 68 ₹1,54,83,719/- as unexplained is untenable. The Ld CIT(A) is noted to have not accepted the reasoning given ... have received SBNs in violation of Government order making SBNs as illegal tender during demonetization period, which cannot be the reason to make addition u/s 68 as held by this Tribunal in the case of Tamil Nadu State Marketing Corporation Ltd. v. ACIT supra. Anyway, as noted