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“Section 133(6)”

Section References (mined)Section 133Section 133(6)6,687 judgments

The decision most relied on for Section 133(6) is CIT v. Simit P. Sheth (356 ITR 451), cited in 1,465 judgments on BharatTax.

Leading authorities on Section 133(6)

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

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.

Raymond Woollen Mills Ltd. v. ITO
236 ITR 34 · 1999 · Supreme Court
862
citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

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. Tata Elxsi Ltd.
349 ITR 98 · 2012 · High Court
818
citing judgments

When computing deduction under Section 10A, if communication or telecommunication expenses are excluded from export turnover, they must also be excluded from total turnover to maintain consistency and apply the ordinary meaning of 'turnover' in context.

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.

(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.

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.

Judgments citing Section 133(6)

Shri. Kempareddy Govindraj, Bengaluru vs. Assistant Commissioner of Income Tax, Central Circle-2(3), Bengaluru

ITA 1022/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jan 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

For Appellant: Shri. V. Chandrasekhar, ARFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

date and observed that as per the affidavit filed, the assessee did not own any jewellery on 01.06.2012. The AO obtained information under section 133(6) of the Act from the Lokayukta about the assets and liabilities. From the information submitted by the Lokayukta, it was noticed that from period

Shri. Kempareddy Govindraj, Bengaluru vs. Assistant Commissioner of Income Tax, Central Circle-2(3), Bengaluru

In the result the appeals of the assessee in ITA No’s 1022 to

ITA 1021/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Jan 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu

For Appellant: ITA Nos.1021 to 1024/Bang/2024
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

date and observed that as per the affidavit filed, the assessee did not own any jewellery on 01.06.2012. The AO obtained information under section 133(6) of the Act from the Lokayukta about the assets and liabilities. From the information submitted by the Lokayukta, it was noticed that from period

Deputy Commissioner of Income Tax-1(3)(1), Mumbai vs. Sps Finquest Limited, Mumbai

ITA 4367/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Jan 2025AY 2017-18

Bench: CIT(A) challenging the above addition/disallowance made by the Assessing Officer. The CIT(A) allowed the appeal preferred by the Assessee and deleted the disallowance of INR.5,48,313/- made under Section 14A of the Act as well as the addition of INR.10,00,00,000/- made under Section 68 of the Act.

For Appellant: Shri Devendra JainFor Respondent: Shri Kishor Dhule
Section 143(3)Section 14ASection 250Section 68

lender as reflected in the Income Tax Returns of the lenders for different Assessment Years and in the response to notice issued under Section 133(6) of the Act sent by the Lender to the Assessing Officer during the Assessment proceedings. 12. On perusal of the order passed ... taken note of the fact that the lender (i.e. Shri Vighnaharta Realty Pvt. Ltd.) had, in response to the notice issued under Section 133(6) of the Act, confirmed the loan transaction; disclosed the source of funds used to give loan to the Assessee and furnished supporting documents. The relevant

Rajendra Agrawal, Biroli Bazar vs. ITO Ward 3(1) Purnea, Purnia

The appeal of the assessee is allowed for statistical purposes

ITA 422/PAT/2024[2011-12]Status: DisposedITAT Patna30 Jan 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.422/Pat/2024 Assessment Year: 2011-12 Rajendra Agrawal.……………….....…..…………………....Appellant New Sipahi Tola, Maranga Road, Bihar – 85301. [Pan: Aqhpa2439E] Vs. Ito, Ward-3(1), Purnia....….…….…............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 27, 2025 Date Of Pronouncing The Order : January 30, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 29.02.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 18 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Care Are That The Assessee Is An Individual & Is Engaged In Farming Activities. The Case Of The Assessee Was Reopened

Section 133(6)Section 143(2)Section 143(3)Section 147Section 249(2)Section 249(2)(c)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA BENCH, PATNA VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and

Dileep Kumar Sah, Siwan vs. ITO Ward2(3), Siwan

The appeal of the assessee is allowed for statistical purposes

ITA 367/PAT/2024[2017-18]Status: DisposedITAT Patna30 Jan 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.367/Pat/2024 Assessment Year: 2017-18 Dileep Kumar Sah……………….....…..…………………....Appellant Makhdoom Sarai, Turha Toli, Siwan, Bihar-841226. [Pan: Gvnps8999L] Vs. Ito, Ward-2(3), Siwan....….…….…............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 28, 2025 Date Of Pronouncing The Order : January 30, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 29.09.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 134 Days In Filing The Present Appeal. The Ld. Ar Of The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause For Such Delay. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Is An Individual & Declared His Return Of Income For The Assessment Year 2017-18 At

Section 133(6)Section 143(2)Section 250Section 250(6)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA BENCH, PATNA VIRTUAL HEARING AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and

Zora Singh, Fatehgarh Sahib vs. Income Tax Officer, Ward - Sirhind, Sirhind

Appeal of the assessee is allowed as and

ITA 669/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 Jan 2025AY 2017-18

Bench: This Tribunal. The Assessee Is Aggrieved

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Smt. Amanpreet Kaur, Addl.CIT DR
Section 133(6)Section 142(1)Section 144Section 250Section 253Section 68

That thereafter, statement of bank account maintained by the assessee for the above referred period was obtained by invoking the provisions of Section 133(6) of the Act. Accordingly, notice under Section 142(1) of the Act alongwith letter providing the assessee opportunity of being heard and requiring the assessee

Stepping Stones Infocom Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2246/KOL/2024[2013-2014]Status: DisposedITAT Kolkata30 Jan 2025AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 131Section 143(2)Section 68

allotment and copy of Form No. 5 for increase in various capital. Further the assessing officer has issued notice to the investors under Section 133(6) on 11.06.2014 for carrying out independent verification of the transaction and those investors duly responded to those notice and filed the requisite details such ... assessee and also cross verified by the assessing officer pursuant to the enquiry conducted in response to the notices issued under Section 133(6) of the Act. The learned Tribunal also referred to the decision of this Court in the case of Crystal Networks Pvt. Ltd. Vs. CIT. reported

Same Deutz Fahr Italia Spa, Italy vs. Assistant Commissioner, Chennai

In the result the appeal of the assessee is allowed

ITA 937/CHNY/2024[AY 2016-17]Status: DisposedITAT Chennai30 Jan 2025

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

For Appellant: Shri. S.P. Chidambaram, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT
Section 147Section 148Section 250o

आयकर अपीलीय अिधकरण,‘सी’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी एबी टी वक", "याियक

Assistant Commissioner of Income Tax, Chennai vs. Evocon Pvt Ltd, Chennai

In the result the appeal of the revenue is dismissed

ITA 1634/CHNY/2024[2017-18]Status: DisposedITAT Chennai30 Jan 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपीलसं/.Ita No.: 1634/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 The Assistant Commissioner Of M/S. Evocon Pvt Ltd Income Tax, V. S Diraviam, No.23, Anaar Flats, 3Rd Floor, Eb Office Road, Central Circle -2(2), Investigation Building, Mogappair East, Chennai – 600 034. Tamil Nadu – 600 037. [Pan:Aacce-9530-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri Nilay Baran Som, Cit अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri S. Sathiyanarayanan, Advocate सुनवाई की तारीख/Date Of Hearing : 12.12.2024 घोषणा की तारीख/Date Of Pronouncement : 30.01.2025

For Respondent: Shri S. Sathiyanarayanan
Section 133(6)Section 14Section 144Section 147Section 148Section 69A

आयकर अपीलीय अिधकरण,‘ ए’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एस एस िव"ने

Asst. Commissioner of Income Tax- 14(1)(2), Mumbai, Aayakar Bhavan Mumbai vs. Foodlink Services India Pvt Ltd, Mumbai

In the result, the appeals of the Revenue for

ITA 4863/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Jan 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Ravikant PathakFor Respondent: Mr. Raj Singh Meel, Sr. DR
Section 143(3)Section 154Section 68

disclosure given at page no. 1121 of the disclosure document [refer page 440-485 of paper book] 8.3 The AO issued notice under section 133(6) of the Act to all the 67 shareholders for verification of their identity and creditworthiness but only 53 shareholders complied with said notices ... remaining 14 shareholders having share capital amounting to Rs.10,44,64,764/- did not respond to the notice issued under section 133(6) of the Act. The AO accordingly added the said sum as unexplained cash credit u/s 68 of the Act. The sum received from the shareholders which

Asst. Commissioner of Income Tax- 14(1)(2), Mumbai, Aayakar Bhavan Mumbai vs. Foodlink Services India Pvt Ltd, Mumbai

In the result, the appeals of the Revenue for

ITA 4854/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Jan 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Ravikant PathakFor Respondent: Mr. Raj Singh Meel, Sr. DR
Section 143(3)Section 154Section 68

disclosure given at page no. 1121 of the disclosure document [refer page 440-485 of paper book] 8.3 The AO issued notice under section 133(6) of the Act to all the 67 shareholders for verification of their identity and creditworthiness but only 53 shareholders complied with said notices ... remaining 14 shareholders having share capital amounting to Rs.10,44,64,764/- did not respond to the notice issued under section 133(6) of the Act. The AO accordingly added the said sum as unexplained cash credit u/s 68 of the Act. The sum received from the shareholders which

Asst. Commissioner of Income Tax- 14(1)(2), Mumbai, Aakar Bhavan vs. Foodlink Services India Pvt Ltd, Mumbai

In the result, the appeals of the Revenue for

ITA 4851/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Jan 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Ravikant PathakFor Respondent: Mr. Raj Singh Meel, Sr. DR
Section 143(3)Section 154Section 68

disclosure given at page no. 1121 of the disclosure document [refer page 440-485 of paper book] 8.3 The AO issued notice under section 133(6) of the Act to all the 67 shareholders for verification of their identity and creditworthiness but only 53 shareholders complied with said notices ... remaining 14 shareholders having share capital amounting to Rs.10,44,64,764/- did not respond to the notice issued under section 133(6) of the Act. The AO accordingly added the said sum as unexplained cash credit u/s 68 of the Act. The sum received from the shareholders which

Nyka Steels Pvt Ltd, Mumbai vs. Commissioner of Income Tax, Mumbai

In the result, the appeal by the assessee is dismissed

ITA 2043/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Jan 2025AY 2018-19

Bench: Shri B. R. Baskaranshri Sandeep Singh Karhailnyka Steels Pvt. Ltd., 10, Peeru Lane, Bhindi Bazar, Mumbai – 400009 Pan : Aaacn1660Q ............... Appellant V/S Pr. Commissioner Of Income Tax-1, Thane. ……………… Respondent

For Appellant: Shri S.D. PathakFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 133(6)Section 138Section 143(2)Section 263Section 9

During the assessment proceedings, the assessee filed the details in respect of sundry creditors. To examine the genuineness of the creditors, notices under section 133(6) of the Act were randomly issued to certain parties. Out of the few parties to whom the notice under section 133(6 ... replies from certain parties were not received. It was further observed from a few replies received in response to the notice issued under section 133(6) of the Act that the opening and closing balance does not match with the details provided by the assessee and parties. Further, the ledger

Income Tax Officer, Kautaliya Bhavan, Bkc vs. Rajnish Bharti HUF, Darukhana

In the result, both the appeals of the assessee are dismissed

ITA 4378/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 Jan 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mr. C.V. JainFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 142(1)Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SUNIL

Income Tax Officer 41(3)(3), Bkc vs. Rajnish Bharti HUF, Darukhana

In the result, both the appeals of the assessee are dismissed

ITA 4377/MUM/2023[2010-11]Status: DisposedITAT Mumbai30 Jan 2025AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mr. C.V. JainFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 142(1)Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SUNIL

Rajnish Bharti HUF, Mumbai vs. The Income Tax Officer 20(3)(1), Mumbai, Lalbaug

In the result, both the appeals of the In the result, both the appeals of the assessee are dismissed assessee are dismissed whereas appeals of the Revenue are allowed

ITA 3941/MUM/2023[2010-11]Status: DisposedITAT Mumbai30 Jan 2025AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mrs. Sanyogita Nagpal, CIT-DRFor Respondent: Mr. C.V. Jain
Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SUNIL

Rajnish Bharti HUF, Mumbai vs. The Income Tax Officer 20(3)(1), Mumbai, Lalbaug

In the result, both the appeals of the In the result, both the appeals of the assessee are dismissed assessee are dismissed whereas appeals of the Revenue are allowed

ITA 3912/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 Jan 2025AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Appellant: Mrs. Sanyogita Nagpal, CIT-DRFor Respondent: Mr. C.V. Jain
Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SUNIL

Jalalabad Solvex Private Ltd, Jalalabad vs. Pr Commissioner of Income Tax, Amritsar-1

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

ITA 117/ASR/2024[2014-2015]Status: DisposedITAT Amritsar29 Jan 2025AY 2014-2015

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Ashwani Kalia, C.A
Section 143(1)Section 143(3)Section 144BSection 147Section 148Section 263Section 263(1)

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR (HYBRID COURT) BEFORE SH. UDAYAN DASGUPTA, JUDICIAL MEMBER AND SH. KRINWANT

Punjabhai Alabhai Madam, Devbhumi Dwarka vs. ITO WD 1 Dwarka, Jamnagar

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

ITA 606/RJT/2024[2018-19]Status: DisposedITAT Rajkot29 Jan 2025AY 2018-19

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 606/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Punjabhai Alabhai Madam, Vs. Ito, Ward 1, 75/1, Vadi Area Bharatpur, Dwarka – 360510, Bhanavad, Nr. Hanuman Mandir, Jamnagar Devbhumi, Dwarka – 360510 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Dfjpm4987R (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 27/01/2025 Date Of Pronouncement : 29/01/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 28.06.2024, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 154 Of The Income Tax Act, 1961 (In Short “The Act”). 2. Grounds Of Appeal Raised By The Assessee Are As Followed: 1) The Ld. Cit(A) Erred In Law As Well As On Facts In Confirming Penalty Of Rs. 65,246/- Imposed By The Ld. Ao U/S. 271B Of The Act.

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 133(6)Section 139(1)Section 144Section 147Section 154Section 271B

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, AM. & DINESH MOHAN SINHA, JM आयकरअपीलसं

Rajendra Mohanlal Agrawal, Jalna vs. Income Tax Officer, Ward-1, Jalna

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

ITA 514/PUN/2024[2017-2018]Status: DisposedITAT Pune29 Jan 2025AY 2017-2018

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Shri Nikhil PathakFor Respondent: Shri Arvind Desai, Addl CIT-DR
Section 131Section 133(6)Section 133ASection 143(1)Section 143(2)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS. ASTHA