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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)

Kameshwar Alloys and Steels Pvt. Ltd., Kolkata vs. ACIT, Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 49/RAN/2024[2014-15]Status: DisposedITAT Ranchi14 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

Section 131Section 132(1)Section 133(6)Section 133ASection 143(3)Section 144Section 153ASection 250Section 68

showing that I.T.A. No.49/Ran/2025 Kameshwar Alloys And Steels Pvt. Ltd all investor companies were active companies. Even, the Assessing Officer issued notices under section 133(6) of the Act to the investor companies, which were duly complied with in all cases except Manpasand Agency Pvt. Ltd., where non-compliance occurred

Income Tax Officer, Ward-I, Mandi Gobindgarh vs. Rohit, Mandi Gobindgarh

The appeal stands dismissed

ITA 905/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh13 Jan 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.905/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) Ito-Ward-1 Shri Rohit Mandi Gobindgarh Shop No.308, Sec-26A बनाम/ At Sirhind, New Libra Kothi Amloh Road, Gobindgarh Vs. Railway Road, Sirhind Fatehgarh Sahib - 147301 Fatehgarh Sahib – 147301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Asopr-3001-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ashok Goyal (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 10-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 12-06- 2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S 144B Of The Act On 24-12-2022. The Sole Grievance Of The Revenue Is Deletion Of Addition Of Rs.1509.90 Lacs As Made By Ld. Ao On Account Of Alleged Bogus Purchases While Framing The Assessment. The Sole Ground Of Appeal Read As Under: - Whether On The Facts & In The Circumstances Of The Case, The Cit(A) / Nfac Was Right In Law In Deleting The Addition Of Rs.15,09,90,967/- As Shown Purchases Expenses Claimed By The Assessee & Nefac Has Added To The Total Income & Taxed As Income From Other Sources U/S 69C Of The Act?

For Appellant: Shri Ashok Goyal (CA) – Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) – Ld. DR (Virtual)
Section 133(6)Section 143(3)Section 145(3)Section 69C

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT

ITO, Ward-3, Yamuna Nagar vs. Raman Kohli, Yamuna Nagar

In the result, both the appeals stand dismissed

ITA 445/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh13 Jan 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.445/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2020-21) & 2.आयकरअपीलसं./ Ita No.437/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) Ito Ward - 3 Raman Kohli Aaykar Bhawan, Sector-17, Huda, C/O Rama Rolling & General Mills बनाम/ Vs. Jagadhari, Haryana – 135003 Old Ambala Road Opp. Hindu Girls College Jagadhari (Haryana) - 135003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Actpk-8263-A (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Ms. Ekta Kumari (Advocate), Ms. Mehak Dhiman (Advocate), Sh. B.M. Monga (Advocate)&Sh. Rohit Kaura (Advocate) – Ld. Ars Revenue By : Sh. Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual Mode) सुनवाईकीतारीख/Date Of Hearing : 10-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Revenue For Assessment Years 2020-21 & 2021-22 Have Been Preferred On Identical Facts & Issues. First, We

For Appellant: Ms. Ekta Kumari (Advocate), Ms. Mehak Dhiman (Advocate)For Respondent: Sh. Bharat Bhushan Garg (CIT) – Ld. DR (Virtual Mode)
Section 133(6)Section 143(3)

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT

ITO, Yamuna Nagar vs. Raman Kohli, Yamuna Nagar

In the result, both the appeals stand dismissed

ITA 437/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh13 Jan 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.445/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2020-21) & 2.आयकरअपीलसं./ Ita No.437/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) Ito Ward - 3 Raman Kohli Aaykar Bhawan, Sector-17, Huda, C/O Rama Rolling & General Mills बनाम/ Vs. Jagadhari, Haryana – 135003 Old Ambala Road Opp. Hindu Girls College Jagadhari (Haryana) - 135003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Actpk-8263-A (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Ms. Ekta Kumari (Advocate), Ms. Mehak Dhiman (Advocate), Sh. B.M. Monga (Advocate)&Sh. Rohit Kaura (Advocate) – Ld. Ars Revenue By : Sh. Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual Mode) सुनवाईकीतारीख/Date Of Hearing : 10-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeals By Revenue For Assessment Years 2020-21 & 2021-22 Have Been Preferred On Identical Facts & Issues. First, We

For Appellant: Ms. Ekta Kumari (Advocate), Ms. Mehak Dhiman (Advocate)For Respondent: Sh. Bharat Bhushan Garg (CIT) – Ld. DR (Virtual Mode)
Section 133(6)Section 143(3)

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT

Satish Nagesh Kulkarni, Secunderabad vs. DCIT., Circle-10(1), Hyderabad

ITA 1025/HYD/2025[2016-17]Status: DisposedITAT Hyderabad13 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1025/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Satish Nagesh Kulkarni, Vs. Dcit, Secunderabad. Circle-10(1), Pan: Begpk9791B Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: None राज" व "ारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 13/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 06/01/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal Before Us:

For Appellant: NoneFor Respondent: Shri K. Vinoth Kannan, Sr
Section 133(6)Section 143(3)Section 68

payments made by the assessee. Also, the AO took cognizance of the fact that the letter that was issued by him under section 133(6) of the Act to the company was not responded by the latter. Further, the AO observed that though the assessee had placed on his record