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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)

Ravindra Kumar Gupta, Ghaziabad vs. DCIT, Circle 5(3)(1), G B Nagar

The appeal of the assessee is allowed and the impugned

ITA 2760/DEL/2025[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Anubhav Sharmaravindra Kumar Gupta Vs. Dcit, Circle 5(3)(1) C/O Ca Vaibhav Goel Gb Nagar 75 Navyug Market Aaykar Bhavan, A-2D, 1St Floor, Ghaziabad Sector – 24 Uttar Pradesh – 201002 Noida, Up- 201307 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahmpg9176E Appellant .. Respondent

For Appellant: Sh. Vaibhav Goel, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr
Section 132Section 144ASection 147Section 148Section 148ASection 151Section 68

P a g e | 1 Ravindra Kumar Gutpa (AY: 2018-19) IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, DELHI

Income Tax Officer, Ward - 10(1), Delhi vs. Goverdhan Transport Company Pvt. Ltd., Delhi

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

ITA 4976/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshincome Tax Officer, Vs. Goverdhan Transport Ward-10(1), Company Pvt. Ltd, Delhi B/2, Tyagi Vihar, Nangloi, Delhi (Appellant) (Respondent) Pan: Aadcg0663R Assessee By : Ms. Rano Jain, Adv Shri Pranshu Singhal, Ca Ms. Mansi Jain, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 03/12/2025 Date Of Pronouncement 09/01/2026

For Appellant: Ms. Rano Jain, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 131Section 133(6)Section 142(1)Section 143(3)Section 37(1)

genuineness of expenses booked in the name of executive remuneration cannot be established by the assessee. The Learned AO also issued notice under section 133(6) of the Act to all the 48 persons who had received remuneration. In the said notice, the employees were asked to provide the details ... returns and copy of Form No. 16. These replies were stated to be filed by the employees in response to notice under section 133(6) of the Act. Hence, it was submitted that no response was filed in response to notice under section 133(6) of the Act before

Deputy Commissioner of Income Tax, Circle-4(2), Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2379/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

that of the AO. It also took note of the fact that notice was issued to the concerned branch of Canara Bank under Section 133(6) of the Act and it was only after information was received from Canara Bank and material evidence furnished by the respondent/assessee, that the addition

DCIT Circle 4(2), New Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2330/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

that of the AO. It also took note of the fact that notice was issued to the concerned branch of Canara Bank under Section 133(6) of the Act and it was only after information was received from Canara Bank and material evidence furnished by the respondent/assessee, that the addition

Kalpesh Ravjibhai Sojitra, Jasdan vs. The Income Tax Officer, Ward 2(1)(2), Rajkot

In the result, appeal filed by the assessee is allowed, in above terms

ITA 487/RJT/2025[2017-18]Status: DisposedITAT Rajkot08 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

For Appellant: Shri Brijesh Parekh, Ld ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 133(6)Section 142(1)Section 147Section 148Section 148ASection 68

आयकर अपीलीय अिधकरण,राजकोट "ायपीठ,राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI

Saurashtra Cement Limited, Porbandar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 307/RJT/2024[2018-19]Status: DisposedITAT Rajkot08 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.307/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2018-19 Saurashtra Cement Ltd. Principal Commissioner Of Near Railway Station, बनाम Income Tax, Jamnagar, Saurashtra Cement Factory, Jamnagar Vs. P.O. Ranavav, Adityana Road, Porbandar, Gujarat-360560 Pan : Aahfs5211J (अपीलाथ"/Assessee) : (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Vimal Desai, Ld.Ar राज" की ओर से/Revenue By : Shri Sanja Punglia, Ld. Cit-Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/01/2026 Order

For Appellant: Shri Vimal Desai, ld.ARFor Respondent: Shri Sanja Punglia, Ld. CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(iii)

आयकर अपीलीय अिधकरण, राजकोट "ायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI

Gopal Mathurdas Parikh, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

In the result, both these appeals are also partly allowed

ITA 408/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2015-16

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil

Gopal Mathurdas Parikh, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

In the result, both these appeals are also partly allowed

ITA 407/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2014-15

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil

Gopal Mathurdas Parikh, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

In the result, both these appeals are also partly allowed

ITA 406/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad08 Jan 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133(6)Section 143(3)Section 148

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil

Pinnacle Consrto and Ecohomes Pvt.Ltd, Pune vs. DCIT Circle-4, Pune

In the result, appeal filed by the assessee is allowed

ITA 2818/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2818/Pun/2025 निर्धारण वषा / Assessment Year : 2017-18 Pinnacle Contro & V Dcit, Ecohomes Pvt. Ltd., S Circle-4, Pune. Madhav Heritage, Tilak Road, Sadashiv Peth, Pune – 411030. Pan: Aaecp0400E Appellant/ Assessee Respondent /Revenue Assessee By Shri Suhas P. Bora Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 07/01/2026 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18Dated 01.10.2025 Emanating From The Assessment Order Passed Under Section 147 Of The Act, Dated 27.08.2021. The Assessee Has Raised The Following Grounds Of Appeal : “1. Reassessment Bad In Law.

Section 143(3)Section 147Section 148Section 151Section 250Section 250(6)

आयकर अपीलीय अधिकरण ”एस एम सी” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “SMC” :: PUNE BEFORE DR.DIPAK

Akshay Anand, Delhi vs. Assessing Officer, Delhi

The appeal of the assessee is allowed for statistical purposes

ITA 2273/DEL/2025[2016-17]Status: DisposedITAT Delhi08 Jan 2026AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Shri Anmol Atrey, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133(6)Section 144Section 147Section 148Section 148ASection 250Section 69

Ignored the absence of any written statements from the Sukhija Group confirming such payments to the appellant. • Failed to issue verification notices under Section 133(6) of the Income Tax Act, which, if issued, would have affirmed the appellant's stance that no such payments were made. • Erroneously construed

Dhirendra Pratap, Lucknow vs. Income Tax Officer-3(2), Ward-3(2), Hardoi

In the result, the appeal of the assessee stands allowed

ITA 467/LKW/2025[2011-12]Status: DisposedITAT Lucknow07 Jan 2026AY 2011-12

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2011-12 Dhirendra Pratap V. The Income Tax Officer A-16/1052, Sector 15 Ward 3(2) Near Vasundhra Complex Hardoi Indira Nagar, Lucknow (U.P) Tan/Pan:Ayepp3148C (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 19.12.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2011-12. 2.0 The Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Year Under Consideration On 06.11.2018 Declaring A Total Income Of Rs.1,75,750/-. The Income Tax Department Was In Possession Of Information That The Assessee Had Deposited Cash To The Tune Of Rs.19,81,000/- In His Bank Account. The Assessing Officer (Ao) Issued A Query Letter Under Section 133(6) Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) On 04.01.2018, Requiring The Assessee To Furnish The Source Of Cash Deposits Along With Other Evidentiary Proof, In Response To Which The Assessee Filed Reply On 07.02.2018. Since

For Respondent: Shri R.R.N. Shukla, D.R
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 154Section 251Section 271(1)(c)

deposited cash to the tune of Rs.19,81,000/- in his bank account. The Assessing Officer (AO) issued a query letter under section 133(6) of the Income Tax Act, 1961 (hereinafter called “the Act’) on 04.01.2018, requiring the assessee to furnish the source of cash deposits along with other

Rakesh Kumar, Barabanki vs. Income Tax Officer, Ward 5(5), Barabanki

The appeal of the assessee stands partly allowed

ITA 438/LKW/2025[2017-18]Status: DisposedITAT Lucknow07 Jan 2026AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Rakesh Kumar V. The Income Tax Officer Naka Paisar Ward 5(5) Deen Dayal Nagar Barabanki Barabanki (U.P) Tan/Pan:Awkpk2247F (Applicant) (Respondent) Applicant By: Shri Rakesh Garg, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 27.12.2023, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Deposited Rs.11,40,000/- During The Demonetization Period, I.E., From 09.11.2016 To 30.12.2016 In His Bank Account No.752530110000014 Maintained With Bank Of India, Subeha Bazar, Haidergarh. Thereafter, The Assessing Officer (Ao) Issued Statutory Notices To The Assessee, Requiring The Assessee To Explain The Source Of Cash Deposits In His Bank Account. Since There Was No Compliance From The Side Of The

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 133(6)Section 144Section 249(4)Section 249(4)(b)Section 68

name and style “M/s Maurya Agro Agencies”. The AO also obtained details of assessee’s bank account from the Bank under section 133(6) of the Act, from which it was found that a sum of Rs.11,40,000/- was deposited during the period of demonetization, out of which Rs.10

Abdul Muqeed Mohammed, Warangal vs. Income Tax Officer, Ward - 1, Warangal

ITA 36/HYD/2025[2018-19]Status: DisposedITAT Hyderabad07 Jan 2026AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 133(6)Section 143(2)Section 143(3)Section 68

31/03/2018. 3 Abdul Muqeed Mohammed vs. ITO 4. The AO to verify the authenticity of the subject creditor, issued notice under section 133(6) of the Act to M/s. A.A. Nayeem Beedi Leaves, Koratla, District Jagtial, wherein he was called upon to furnish certain details, viz., (i) nature of transactions ... notes. However, the aforementioned party, viz., M/s. A.A. Nayeem Beedi Leaves, Koratla, District Jagtial, failed to respond to the aforesaid notice issued under section 133(6) of the Act till the culmination of the assessment. 5. The AO based on the fact that the subject creditor, viz., M/s. A.A. Nayeem

Pandian Hari, Chennai vs. The Income Tax Officer Non Corp Ward 11(40, Chennai

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

ITA 2598/CHNY/2025[2017-2018]Status: DisposedITAT Chennai07 Jan 2026AY 2017-2018

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 2598/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Shri Pandian Hari, The Income Tax Officer, 75/151 I Om Sri Sairam Plaza, Vs. Non-Corporate Ward 11(4), Thambuchetty Street, Chennai Parrys, Chennai – 600 001. Pan: Acfph 7870Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Dr.S. Sankar Ganesh, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 07.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 07.01.2026

For Appellant: Dr.S. Sankar Ganesh, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 115BSection 133(6)Section 143(3)Section 145(3)Section 250Section 68

आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी जॉज" जॉज

Ramaniyam Real Estates Pvt. Ltd., Chennai vs. ACIT, Circle-I, Ltu, Chennai

In the result, the appeal filed by the assessee are allowed for statistical

ITA 2439/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 2439/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Ramaniyam Real Estates Private Limited. 17/35, Ii Main Road, Besant Nagar, Chennai - 600 020. [Pan: Aaacr-2276-A] (अपीलार्थी/Appellant) Acit, Vs. Circle -1, Ltu, Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Girish Kumar, Advocate प्रत्यर्थी की ओर से/Respondent By : Ms. Gauthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 03.12.2025 घोषणा की तारीख/Date Of Pronouncement : 07.01.2026 आदेश /Order Per S. R. Raghunatha, Am : This Appeal Filed By The Assessee Is Directed Against Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Herein After “Ld.Cit(A)] Dated 13.08.2025 & Pertains To

For Appellant: Shri. Girish Kumar, AdvocateFor Respondent: Ms. Gauthami Manivasagam, JCIT
Section 133(6)Section 143(3)Section 194Section 194CSection 194JSection 40

facts and in law. 8. The NFAC, Delhi ought to have appreciated that having not exercised the power vested in terms of Section 133(6) of the Act in calling for the details regarding the statement of income from the parties to whom the payments were made by the appellant

Income Tax Officer-19(1)(1), Mumbai vs. Babulal Mishrimalji Mehta, Mumbai

In the result, the grounds of appeal raised by the revenue are

ITA 6131/MUM/2025[2019-20]Status: DisposedITAT Mumbai07 Jan 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Arun Khodpia(Physical Hearing) Income Tax Officer-19(1)(1), Babulal Mishrimalji Mehta 501, 5Th Floor, Piramal Chamber, Vs 7 Marker Building, Office No.91St Lalbaug, Mumbai Panjarapole Lane, Mumbai [Pan:Afbpm0921N] Appellant / Assessee Respondent / Revenue

Section 254(1)Section 68Section 69C

assessee reiterated his submission and contended that evidence furnished by assessee was not considered. Mere non-responsive to the notice under Section 133(6), it does not automatically imply that transaction is not genuine, specifically when assessee provided complete corroborative 5 Babulal Mishrimalji Mehta (A.Y. 2019-20) documentary evidence ... absence of purchases. Though, we find that the Assessing Officer carried out investigation through verification unit, not only by sending notices under section 133(6), but through physical verification. One party namely NSG Metal was not traceable at the given address. The postal article of notice to other party namely

Asstt. Commisioner, Mumbai vs. Supreme Lake View Bungalows Private Limited, Powai, Mumbai

In the result the appeal of the revenue bearing ITA No

ITA 5735/MUM/2025[2022]Status: DisposedITAT Mumbai07 Jan 2026

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 139Section 143(1)Section 143(3)Section 250Section 36(1)(iii)Section 68

pointed out any defect in The documents. As a matter of fact, AO had not even issued a notice under section 133(6) to the share applicant, if he had any doubt regarding creditworthiness of the share applicant. Balance sheet of share applicant showed ample source of funds, hence

Kaishar Interiors Private Limtied, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(2)(2), Mumbai

Accordingly Ground No.16 raised by the Assessee is allowed

ITA 5665/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Dinesh Kukreja &For Respondent: Shri Hemanshu Joshi
Section 143(3)Section 147Section 148Section 14A

using register like Q.C. Register, Stock Registere etc. for specific Batch Number). The Assessing Officer had further recorded that the notice issued under Section 133(6) of the Act to the above parties were returned un-served with the remarks ‘left/not known’. Even in the appeal preferred by the Assessee ... failed to file any document showing delivery of goods is factually incorrect. The Learned Authorised Representative had also disputed that notice under Section 133(6) of the Act were issued and/or the same were returned back as un-served and had placed on record copy of RTI application, dated 05/09/2025

Ashish Girish Jain, Mumbai vs. ITO, Ward 42(1)(1), Mumbai

ITA 5328/MUM/2025[2010-11]Status: DisposedITAT Mumbai07 Jan 2026AY 2010-11

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajesh ShahFor Respondent: Shri Pradipsinh Saktavat
Section 132Section 143(1)Section 143(3)Section 147Section 148

independent inquiry was carried out by the Assessing Officer. There is nothing on record that any notice (show cause notice or notice under Section 133(6) of the Act) was issued by the Assessing Officer during the course of assessment proceedings. Therefore, we find merit in the contention advanced