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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)

ACIT, Anand Circle, Anand vs. Narendrakumar Hansrajbhai Patel, Kheda

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

ITA 834/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.834/Ahd/2024 िनधा"रण वष" /Assessment Year : 2021-22 The Acit Narendrakumar Hansrajbhai बनाम/ Dy./Asst.Commissioner Of Patel V/S. Income Tax (Anand Circle) I C/O. Mahakali Saw Mill Anand – 388 001 Mansarovar Marker Kamla Kamia, Kheda – 387 320 "थायी लेखा सं./Pan: Cmmpp 6784 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mishal Mehta, Ca Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/08/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/02/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2021-2022. 2. The Revenue Has Raised The Following Grounds Of Appeal: “1. Whether, On Facts & In Circumstances Of The Case & In Law, The Ld.Cit(A) Is Justified In Deleting The Addition Of Rs. 10,64,04,151/-Made U/S 69C Of The Act Without Appreciating The Fact The Assessee Failed To Substantiate The Expenditure Claimed With Supporting Evidences? Asst.Cit Vs. Narendrakumar Hansrajbhai Patel Asst. Year : 2021-22

For Appellant: Shri Mishal Mehta, CAFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 133(6)Section 143(3)Section 250Section 69C

suppliers from whom purchases were made were either non-filers or had declared meagre income in their returns. The AO issued notices under section 133(6) of the Act to these parties to verify the genuineness of the purchases. Out of 17 parties, confirmations were received only from

Bombay Tyres, Mumbai vs. Income Tax Officer -15(1)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2393/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Oct 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18 Bombay Tyres Vs Income-Tax Officer, 23, Arenja Corner, -15(1)(1), Sector-17, Vashi, Mumbai Navi Mumbai – 400703 [Pan: Aagcb1604E] Appellant Respondent Present For: Assessee : Shri Tanzil Padvekar & Shri Gopal Sharma, Advocates Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 06.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2023-24/1057354062(1), Dated 26.10.2023 Passed Against The Assessment Order By National Faceless Assessment Centre, Delhi U/S.144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 28.06.2019 For Ay 2017-18. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. Considering The Facts & Circumstances Of The Case & In Law, The National Faceless Appeal Centre (Nfac) Has Erred In Confirming The Order U/S. 144 R.W.S. 144A Dated 28Th June, 2019 Passed By The Assessing Officer Without Appreciating The Merits Of The Case.

For Appellant: Shri Tanzil Padvekar and Shri Gopal Sharma, AdvocatesFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 144Section 250Section 44ASection 69A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

ACIT 4(3)(1), Mumbai vs. Narayan Dalpatram Thakkar, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3619/MUM/2017[2008-09]Status: DisposedITAT Mumbai29 Oct 2025AY 2008-09

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2008-09 Assistant Commissioner Of Vs Narayan Dalpatram Income-Tax - 4(3)(1), Thakkar Mumbai Abhay Bldg, 5Th Floor, Ns 9Th Rdm Jvpd Scheme, Juhu Vile Parle (W), Mumbai - 400032 [Pan: Aaipt0713F] Appellant Respondent Present For: Assessee : Shri Parag Shah, Ca Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Cit(A) – 9, Mumbai, Vide Order No. Cit(A)-9/Cir.4/529/2015-16, Dated 17.03.2016 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax-4(3)(1), U/S.143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 29.01.2016 For Ay 2008-09. 2. Grounds Taken By The Revenue Are Reproduced As Under: “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Directing The Ao To Delete The Addition Made Towards Unexplained Unsecured Loan Of Rs.65,00,000/- U/S.68 Of The I.T. Act.

For Appellant: Shri Parag Shah, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(3)Section 148Section 68Section 69C

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT