“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)

Firstrand Bank Limited - India Branch, Mumbai vs. Assistant Commissioner, Mumbai

In the result, appeal of the assessee is allowed

ITA 4580/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Paras Savla, AdvocateFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 133(6)Section 144C(5)Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Motibhai Revabhai Prajapati, Ahmedabad vs. ITO, Ward-3(3)(5), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1454/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Parin Shah, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R

Section 115BSection 133(6)Section 133ASection 271ASection 69Section 69A

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH Before Dr. BRR Kumar, Vice President And Ms. Suchitra Kamble, Judicial Member

Selvarajan Senthil Kumar, Thanjavur vs. Income Tax Department, Thanjavur

The appeal is allowed

ITA 3158/CHNY/2025[2017-18]Status: DisposedITAT Chennai09 Mar 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Ms. Ramya Murlikumaran, AdvocateFor Respondent: Shri. Saujanya Ranjan, JCIT

Section 133(6)Section 143(3)Section 250Section 69Section 69A

आयकर अपील"य अ"धकरण, ‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी एस एस

E2E Supply Chain Solutions Limited, Chennai vs. ACIT, Corporate Circle 1(1), Chennai

In the result, the appeal for AY 2008-09 is treated as allowed for statistical purposes in terms of above order

ITA 3101/CHNY/2025[2013-14]Status: DisposedITAT Chennai09 Mar 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos. 3100 & 3101/Chny/2025 "नधा"रण वष"/Assessment Years: 2008-09 & 2013-14 M/S. E2E Supply Chain V. Assistant Commissioner Solutions Limited, Of Income Tax, 4Th Floor, East Coast Centre, Corporate Circle -1(1), 534, Anna Salai, Teynampet, Chennai. Chennai – 600 018. [Pan: Aabce 7932 P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. S. Dwarakesh, C.A. ""यथ" क" ओर से /Revenue By : Ms. R. Anitha, Addl. Cit सुनवाईक"तार"ख/Date Of Hearing : 02.03.2026 घोषणाक"तार"ख /Date Of : 09.03.2026 Pronouncement आदेश / O R D E R Per Manu Kumar Giri, Jm:

For Appellant: Mr. S. Dwarakesh, C.AFor Respondent: Ms. R. Anitha, Addl. CIT

crores. However, substantial expenditure constituting the major component of the operational cost has been disallowed primarily on the ground that notices issued under section 133(6) were either not complied with or returned unserved. From the records, it is evident that the assessee had furnished complete particulars of the transporters

E2E Supply Chain Solutions Limited, Chennai vs. ACIT, Corporate Circle 1(1), Chennai

In the result, the appeal for AY 2008-09 is treated as allowed for statistical purposes in terms of above order

ITA 3100/CHNY/2025[2008-09]Status: DisposedITAT Chennai09 Mar 2026AY 2008-09

For Appellant: Mr. S. Dwarakesh, C.AFor Respondent: Ms. R. Anitha, Addl. CIT

Chhaya Ketan Mehta, Mumbai vs. Income Tax Officer - 33(1)(3), Mumbai

In the result, appeal of the assessee is allowed

ITA 6543/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Nishit Gandhi, AdvFor Respondent: Shri Virabhadra Mahajan (Sr. DR)

Section 10(38)Section 14Section 143(3)

IN THE INCOME-TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT

Kamlesh Koushal, Indore vs. Income Tax Officer, 1(2), Indore

In the result, the impugned order is set aside as & by way of

ITA 708/IND/2025[2017-18]Status: DisposedITAT Indore06 Mar 2026AY 2017-18

Bench: Shri B.M. Biyani & Shriparesh M Joshi

Section 133(6)Section 142(1)Section 144Section 246ASection 250Section 253Section 272A(1)(d)Section 274Section 69A

sTaPsiieasiupew, sds sale IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRIPARESH

Income Tax Officer, Ward-9(1), Kolkata vs. Littlestar Securities Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 694/KOL/2025[2012-13]Status: DisposedITAT Kolkata06 Mar 2026AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Manjeet Singh, DR

Section 143(3)Section 144BSection 254Section 68

that case involved non-existent or phantom entities, whereas in the present case the investors were traceable taxpayers who confirmed the transactions under Section 133(6). Additionally, for AY 2009-10, the "source of source" requirement was inapplicable since the proviso to Section 68 introduced by the Finance ... dealt with "phantom" entities where notices were returned unserved. In the present case, the investors are traceable taxpayers who confirmed the transactions through Section 133(6) responses. To equate "traceable investors" with "phantom entities" is a leap in logic that this Court cannot countenance. 9. Furthermore, for the Assessment Year

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2922/KOL/2025[2022-23]Status: DisposedITAT Kolkata06 Mar 2026AY 2022-23

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

identity, creditworthiness of the loan creditor and genuineness of the transactions. The said loan creditor has complied with the notice issued under section 133(6) of the Act. There is no finding in the assessment order with respect to aforesaid documents filed at the assessment hearing stage. Thus ... details such as copy of ledger account, bank statements, income tax returns, balance sheet etc. It was also recorded that notice under Section 133(6) of the Act was issued to the said parties which were duly responded by them. The identity of the parties could not be, therefore disputed

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2921/KOL/2025[2020-21]Status: DisposedITAT Kolkata06 Mar 2026AY 2020-21

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

Mescab India Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2128/KOL/2025[2014-2015]Status: DisposedITAT Kolkata06 Mar 2026AY 2014-2015

Bench: the AO all the evidences qua these unsecured loans such as names, addresses, PANs, audited accounts, confirmations etc. The also AO issued letters to all the loan creditors u/s 133(6) of the Act which were all replied by the loan creditors by furnishing all the details such as copies of the ITRs, audited balance sheets, bank statements, loan confirmation etc. as called for by the AO. However, the AO, by making casual remarks about money laundering and rejecting all the evidences, treated th

Section 133(6)Section 250Section 68

effect of the statement of AKA also took note of the fact that the notices which were issued by the Assessing Officer under section 133(6) to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal ... details such as copy of ledger account, bank statements, income tax returns, balance sheet etc. It was also recorded that notice under Section 133(6) of the Act was issued to the said parties which were duly responded by them. The identity of the parties could not be, therefore disputed

Mescab India Private Limited, Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2127/KOL/2025[2013-2014]Status: DisposedITAT Kolkata06 Mar 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 133(6)Section 250Section 68

Income Tax Officer, Ward-3(1), Kolkata vs. A J Cast Alloys Private Limited, Howrah

ITA 1685/KOL/2024[2011-12]Status: DisposedITAT Kolkata06 Mar 2026AY 2011-12

Section 132(1)Section 133(6)Section 143(1)Section 147Section 148Section 250Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER I.T.A

DCIT, CC-1(4), Kolkata vs. Ambica Dhatu Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2389/KOL/2025[2012-13]Status: DisposedITAT Kolkata05 Mar 2026AY 2012-13

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 131Section 133(6)Section 250

Officer in para 6.4. The Ld. CIT(A) noted that ,in the remand proceedings, the Assessing Officer was asked to conduct enquiry under Section 133(6) of the Act from three parties and the Assessing Officer accordingly conducted enquiry from three parties and submitted remand report on the same ... noted that the six parties also complied to the notices issued under Section 133(6) of the Act by Assessing Officer. Finally, the Ld. CIT(A) deleted the addition by relying on the decision of Hon'ble Supreme Court in the case of CIT Vs. Lovely Exports

Veeresh Wali, Bengaluru vs. Income Tax Officer, Ward-2(2)(2), Bangalore

In the result, the appeal of the assessee is hereby allowed

ITA 2413/BANG/2025[2017-18]Status: DisposedITAT Bangalore05 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Siva Prasad Reddy, ITPFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 133(6)Section 142(1)Section 143(3)Section 250Section 263Section 69A

under section 142(1) of the Act along with supporting documents. However, for the purpose of independent verification, the AO issued notice under section 133(6) of the Act to M/s. Visvesvaraya Co-operative Bank Ltd. calling for the bank statements and transaction details. 7.1 On perusal of the details

Asst. Commissioner of Income Tax, Central Circle-1, Mangalore vs. Raj Diamonds, Mumbai

In the result the appeal of the Revenue is dismissed &

ITA 1361/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Mar 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Subramanian, D.R

Section 132Section 143(1)Section 143(2)Section 144(3)Section 148Section 153CSection 250

ITANo.1361/Bang/2025 & CO 20/Bang/2025 M/s. Raj Diamonds, Mumbai IN THE INCOME TAX APPELLATE TRIBUNAL “B’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI

Adimulam Satyanarayana Proprietor, Vizianagaram vs. Income Tax Officer, Ward-2, Vizianagaram

In the result, appeal filed by the assessee is allowed in terms of my aforesaid observations

ITA 472/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam04 Mar 2026AY 2017-18

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

Section 115BSection 13Section 133(6)Section 139(4)Section 142(1)Section 143(2)Section 144Section 69A

comply with the aforesaid notice and did not come forth with any return of income. 5. Thereafter, the AO issued notice under section 133(6) of the Act, to State Bank of India, Srugavarapukota Branch, Vizianagaram and called for the statement of the bank account held by the assessee with

Srinivasa Rao Sirivuri Proprietor, Vizianagaram vs. Income Tax Officer, Vizianagaram

In the result, appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 459/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam04 Mar 2026AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 44ASection 69A

copy of the assessee’s bank account number 225811100000034 held with Andhra Bank (now merged with Union Bank of India) under section 133(6) of the Act. The A.O on perusal of the copy of the bank account of the assessee as was made available to him, observed that

Pedaveeti Swathi, Hyderabad vs. ITO, Ward 9(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 1785/HYD/2025[2016-17]Status: DisposedITAT Hyderabad04 Mar 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1785/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Pedaveeti Swathi, Vs. Income Tax Officer, Hyderabad. Ward-9(1), Pan: Fugps2126J Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Chaitanya Kumar, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 26/02/2026 घोषणा की तारीख/Date Of 04/03/2026 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 03/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 27/02/2024 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri T. Chaitanya KumarFor Respondent: Dr. Sachin Kumar, Sr.AR

Section 115BSection 142(1)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 69A

details. As the assessee failed to furnish the requisite details and respond to the aforesaid notice, therefore, the AO issued a notice under section 133(6) of the Act, dated 17/10/2023 to ICICI Bank Limited, wherein it was called upon to furnish a copy of the bank statement

Late Abdullah Abdulmajeed, Rep. by L/H, Pudukkottai vs. ITO, Ward-1, Pudukkottai

ITA 3294/CHNY/2025[2015-16]Status: DisposedITAT Chennai04 Mar 2026AY 2015-16

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 148ASection 69A

आयकर अपीलीय अधिकरण 'बी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH: CHENNΑΙ सुश्री पद्मावती एस, लेखा सदस्य