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“addition u/s 68”

Cash Credits & Unexplained ItemsSection 68Section 682,598 judgments

The decision most relied on for addition u/s 68 is CIT v. Lovely Exports (P) Ltd. (216 CTR 195), cited in 854 judgments on BharatTax.

Leading authorities on addition u/s 68

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. Divine Leasing & Finance Ltd.
299 ITR 268 · 2008 · High Court
426
citing judgments

The Assessing Officer cannot add share capital or share premium amounts if the assessee provides the identity and creditworthiness of the subscriber and establishes the genuineness of the transaction. The court may admit additional evidence under Rule 46A, such as the PAN identity of the creditor.

CIT v. Devi Prasad Vishwanath Prasad
72 ITR 194 · 1969 · Supreme Court
272
citing judgments

If there is an unexplained cash credit, the Assessing Officer can treat it as the assessee's income, even when the income is finalized on an estimation basis, without proving its specific source. The onus then shifts to the assessee to prove that the income represented by the cash credit has already been taxed.

CIT v. Dwarkadhish Investment (P) Ltd.
330 ITR 298 · 2011 · High Court
218
citing judgments

An assessee cannot be asked to explain the source of the source for cash credits, particularly share capital or share application money, once they have discharged the initial onus regarding the identity, genuineness of the transaction, and creditworthiness of the immediate investor.

1) CIT v. Sahibganj Electric Cables Pvt. Ltd. (
151 ITR 150 · 1985 · High Court
79
citing judgments

The assessee's burden under Section 68 to prove cash credits is discharged by establishing the identity of the creditor and the genuineness of the transaction; the assessee is not required to prove the creditor's source of funds or creditworthiness, as the department can use Section 131 for further investigation.

Jatia Investment Co. v. CIT
206 ITR 718 · 1994 · High Court
77
citing judgments

An addition under Section 68 for unexplained cash credits cannot be made when there is no actual cash credit or flow of funds, such as in cases of share swaps or notional credits.

Hastimal v. CIT
49 ITR 273 · 1963 · High Court
57
citing judgments

An assessee's duty regarding the creditworthiness of a creditor is limited to the transactions between them, and they are not required to investigate the ultimate source of the creditor's funds. If the genuineness of the transaction and the creditworthiness are established, no addition under Section 68 is permissible.

CIT v. Prameshwar Bohra
301 ITR 404 · 2008 · High Court
47
citing judgments

An amount already credited in the books of account in an earlier assessment year cannot be added again as an unexplained cash credit under Section 68 of the Income-tax Act in a subsequent assessment year.

Judgments citing addition u/s 68

Assistant Commissioner of Income Tax, Allahabad vs. Jyoti Mediservices Ltd., Allahabad

ITA 129/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

That in view of the facts and circumstances of the case and in law, the CIT(A) has erred in upholding the addition u/s 68 of the Act of Rs.72,09,500/- made by the Assessing Officer for credit balances / unsecured loan from various parties. I.T.A. Nos.113, 114, 115 & 129/Alld/2025

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 115/ALLD/2025[2013-14]Status: DisposedITAT Allahabad21 Nov 2025AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

That in view of the facts and circumstances of the case and in law, the CIT(A) has erred in upholding the addition u/s 68 of the Act of Rs.72,09,500/- made by the Assessing Officer for credit balances / unsecured loan from various parties. I.T.A. Nos.113, 114, 115 & 129/Alld/2025

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 114/ALLD/2025[2012-13]Status: DisposedITAT Allahabad21 Nov 2025AY 2012-13

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

That in view of the facts and circumstances of the case and in law, the CIT(A) has erred in upholding the addition u/s 68 of the Act of Rs.72,09,500/- made by the Assessing Officer for credit balances / unsecured loan from various parties. I.T.A. Nos.113, 114, 115 & 129/Alld/2025

Jyoti Mediservices Private Limited, Allahabad vs. DCIT, Central Circle, Allahabad

ITA 113/ALLD/2025[2011-12]Status: DisposedITAT Allahabad21 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(2)Section 153ASection 153DSection 271(1)(c)Section 68

That in view of the facts and circumstances of the case and in law, the CIT(A) has erred in upholding the addition u/s 68 of the Act of Rs.72,09,500/- made by the Assessing Officer for credit balances / unsecured loan from various parties. I.T.A. Nos.113, 114, 115 & 129/Alld/2025

ITO, Exemption Ward, Salem vs. Anbu Educational Trust, Komarapalayam

In the result, the appeal of the Revenue is allowed

ITA 332/CHNY/2019[2013-14]Status: DisposedITAT Chennai21 Nov 2025AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.186/Chny/2019, Assessment Years: 2013-14

For Appellant: T.Vasudevan, AdvocateFor Respondent: Mr.Saujanya Rajan, JCIT(Virtual)
Section 11Section 40Section 68

section. It was argued that once the identity of the creditor was established, its credit worthiness and genuineness of transaction was established, no addition u/s 68 was permissible. To this effect the Ld.Counsel submitted that the conclusion of the Ld.CIT(A) / Ld.AO were flawed. Reliance was placed, inter-alia, upon

Anbu Educational Trust Komarapalayam, Komarapalayam vs. ITO, Ward-5, Namakkal

In the result, the appeal of the Revenue is allowed

ITA 186/CHNY/2019[2013-14]Status: DisposedITAT Chennai21 Nov 2025AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.186/Chny/2019, Assessment Years: 2013-14

For Appellant: T.Vasudevan, AdvocateFor Respondent: Mr.Saujanya Rajan, JCIT(Virtual)
Section 11Section 40Section 68

section. It was argued that once the identity of the creditor was established, its credit worthiness and genuineness of transaction was established, no addition u/s 68 was permissible. To this effect the Ld.Counsel submitted that the conclusion of the Ld.CIT(A) / Ld.AO were flawed. Reliance was placed, inter-alia, upon

Jsm Oilfields Services Pvt. Ltd, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, appeal of the assessee is allowed

ITA 4093/DEL/2024[2013-14]Status: DisposedITAT Delhi21 Nov 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2013-14] Jsm Oilfields Services Pvt.Ltd., Vs Dcit, Farm No.14, 8Th Avenue, Radhey Circle-13(1), Mohan Drive, Gadaipur, New Delhi New Delhi-110017. Pan-Aabcj1500C Appellant Respondent Appellant By Shri Anil Jain, Adv. Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 26.08.2025 Date Of Pronouncement 21.11.2025

Section 131Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 68

making following additions / disallowances vide order dated 30.03.2016 passed u/s 143(3) of the Act: (i) addition u/s 68 on account of unexplained cash credit in the books of assessee company of INR 2,10,20,000/-; (ii) disallowance on account of personal expenses ... year before us is AY 2013-14 thus this amendment is not applicable Regarding surrounding circumstances, it is observed that while making addition u/s 68 of the Act, the AO has doubted the financial capacity of subscriber companies but such addition cannot be made on preponderance of probability and there

Gold Spice Impex, Delhi vs. Income Tax Officer, Ward-47(2), Delhi

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

ITA 2244/DEL/2024[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarm/S. Gold Spice Impex, Vs. Ito, Ward 47 (2), 1879, Kucha Chelian, Khari Boali, Delhi. Delhi – 110 006. (Pan : Aapfg0688P) (Appellant) (Respondent) Assessee By :Shri Rakesh Gupta, Advocate Shri Deepesh Garg, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 26.08.2025 Date Of Order : 21.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 17.01.2024 For The Assessment Year 2017-18 Raising Following Grounds Of Appeal :- “1. That Having Regard To The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Action Of Ld. Ao In Making Aggregate Addition Of Rs.1,15,00,000/- On Account Of Cash Deposits U/S 68 & Taxing The Same U/S 115Bbe & That Too By Recording Incorrect Facts & Findings & Without Following The Principles Of Natural Justice.

For Appellant: Shri Rakesh Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 115BSection 143(2)Section 234BSection 68

recorded concocted sales to declare the cash sales and accordingly, he rejected the contentions of the assessee and proceeded to make the addition u/s 68 of the Act to the extent of Rs.1,15,00,000/- u/s 68 of the Act and also invoked the provisions of section 115BBE

Prem Grain Industries Pvt. Ltd, Jalgoan vs. DCIT Circle 1, Jalgaon

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

ITA 2012/PUN/2025[2016-17]Status: PendingITAT Pune20 Nov 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Prem Grain Industries Pvt. Ltd. Dcit, Circle – 1, Jalgaon E 2/1, Midc Area, Ahjantha Vs. Road, Jalgaon – 425003 Pan: Aadcp9598E (Appellant) (Respondent) Assessee By : Shri Suresh Anchaliya Department By : Shri S. Sadananda Singh, Jcit Date Of Hearing : 11-11-2025 Date Of Pronouncement : 20-11-2025 O R D E R Per R.K. Panda, Vp: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.07.2025 Of The Ld. Cit(A), Pune-12 Relating To Assessment Year 2016-17. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Company & Filed Its Return Of Income On 01.09.2016 Declaring Total Income Of Rs.Nil. The Return Was Processed U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). The Case Was Selected For Limited Scrutiny Through Cass For The Following Issue: “Whether Unsecured Loans Are Genuine & From Disclosed Sources.”

For Appellant: Shri Suresh AnchaliyaFor Respondent: Shri S. Sadananda Singh, JCIT
Section 131Section 132Section 132(4)Section 133(6)Section 143(1)Section 143(2)Section 144Section 68

instant case has conclusively proved the identity, creditworthiness and genuineness of the transaction, therefore, there is no justification for making the addition u/s 68 of the Act. 15. The Ld. DR on the other hand heavily relied on the orders of the Assessing Officer

Manish Jashwantrai Bhuta, Nashik vs. ITO Ward 1(1), Nashik

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

ITA 1502/PUN/2025[2016-17]Status: DisposedITAT Pune20 Nov 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Manish Jashwantrai Bhuta Ito, Ward 1(1), Nashik Flat No.8, Pooja Apartment, Vs. Shivam Nagar, Hirawadi, Panchavati, Nashik – 422003 Pan: Aghpb1619F (Appellant) (Respondent) Assessee By : Shri Sanket M Joshi (Through Virtual) Department By : Shri Manish M. Mehta Date Of Hearing : 03-11-2025 Date Of Pronouncement : 20-11-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sanket M Joshi (through virtual)For Respondent: Shri Manish M. Mehta
Section 132Section 147Section 148Section 148ASection 151Section 153CSection 68

Jurisdictional Bombay High Court in case of Coca Cola India (P) Ltd [368 ITR 487] 7] The assessee submits that the addition u/s 68 of Rs.5,12,02,695 made by the A.O. by holding that the entire cash deposits made in bank account with Renuka Mata Credit

Sneha Binoy Shah, Mumbai vs. ITO Circle 19(3), Mumbai

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

ITA 5007/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Nov 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal & Smt.Renu Jauhri7 (A.Y.2017-18)

For Appellant: Shri Smit C. Jhaveri, CA a/w ShriFor Respondent: Shri Ritesh Misra- CIT DR
Section 142(1)Section 144Section 147Section 148Section 234ASection 250Section 68Section 69C

Certificate and insurance claims were submitted during the appeal to justify reason for delay in filing the said appeal. GOA No 2: Addition u/s 68 being LTCG on sale of shares amounting to Rs 61.05.510/- • The Ld. CIT(A) erred in confirming the disallowance the LTCG on sales of shares

Innovative Telecom and Softwares Private Ltd, Surat vs. Assistant Commissioner of Income Tax, Circle-1(1)(2), Surat

In the result, the appeal of the assessee is allowed

ITA 796/SRT/2023[2017-18]Status: DisposedITAT Surat19 Nov 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.796/Srt/2023 Assessment Year: (2017-18) (Hybrid Hearing) M/S Innovative Telecom & Vs. Acit, Softwares Pvt. Ltd., Circle – 1(1)(1), O/21-22, Kanaknidhi Apartment, Surat Nanpura, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaci8036R (Appellant) (Respondent) Appellant By Shri Hiren M. Diwan, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 21/08/2025 Date Of Pronouncement 19/11/2025

Section 115BSection 142(1)Section 143(2)Section 144Section 145(3)Section 250Section 68

period of demonetization. In view ITA No.796/SRT/2023/AY 2017-18 Innovative Telecom & Softwares Pvt. Ltd. of the same, the CIT(A) sustained the addition u/s 68 of the Act of Rs.2,25,99,000/- and dismissed the appeal of the assessee. 8. Aggrieved by the order of CIT(A), assessee filed ... also relied on the decision of ITAT, Hyderabad in case of Vaishnavi Bullion Pvt. Ltd. vs. ACIT, ITA No.560 & 561/Hyd/2020, dated 28.11.2022, wherein addition u/s 68 of the Act was upheld in the hands of the assessee. Since the appellant had not submitted complete details of the debtors from whom

Joint Commissioner of Income Tax, Ajmer vs. Vijeta Lodha, Jaipur

58. As a result, the impugned order by Learned CIT(A) deleting the

ITA 390/JPR/2023[2015-16]Status: DisposedITAT Jaipur19 Nov 2025AY 2015-16
For Appellant: Shri Rajeev Sogani, C.A. (through V.C.)For Respondent: None
Section 10(38)Section 142(1)Section 143(2)Section 68Section 69C

year 2015-16, read as under:- “1.Addition u/s 68 on account of LTCG 2. Addition u/s 69C on account of commission paid 3. Addition u/s 68 on account of STCG 4. Addition u/s 69C on account of commission paid Rs.65,63,180/- Rs.1,42,604/- Rs.7765/- Rs.2155/-" In view

Anirudh Khemka, Kolkata vs. ITO, Ward 30(7), Kolkata

In the result, the appeal of the assessee is allowed

ITA 185/KOL/2025[2017-18]Status: DisposedITAT Kolkata19 Nov 2025AY 2017-18

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

Section 131Section 133(6)Section 142(1)Section 143(2)Section 68

assessee after taking into account the submission/ evidences filed during the Couse of appellate proceedings. The Id. CIT (A) confirmed the addition u/s 68 of the Act in respect of 14 loan creditors as made by the Id. AO u/s 68 of the Act without correctly appreciating the facts ... notice u/s 133(6) of the Act or to the summons u/s 131 of the Act cannot be a ground for making addition u/s 68 of the Act. The assessee has filed all the evidences qua the loan creditors before the authorities below. The case of the assessee find support

Quiver Commercial (P) Ltd., Kolkata vs. I.T.O., Ward - 1(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1700/KOL/2024[2009-2010]Status: DisposedITAT Kolkata19 Nov 2025AY 2009-2010

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 1(2), Kolkata Quiver Commercial (P) Ltd. Aaykar Bhawan, P-7, 3, Amartalla Street, Burrabazar, Chowringhee Square, Vs. Kolkata-700001, West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aaacq1349R Assessee By : Shri Giridhari Dhelia, Ar Revenue By : Shri Guru Bhashyam, Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri Giridhari Dhelia, ARFor Respondent: Shri Guru Bhashyam, DR
Section 131Section 142(1)Section 143(3)Section 147Section 148Section 263Section 68

discharged its onus by filing all the evidences before the ld. AO as well as before the ld. CIT (A). Moreover, the addition u/s 68 of the Act cannot be made merely on the ground of low income, meagre revenue or low fixed assets and reserves and surplus. The case

Gayatri Sewa Sansthan, Uttar Pradesh vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Ghaziabad

In the result, the assessee will get relief of INR 90 Lakhs of the loan taken from M/s

ITA 3978/DEL/2025[2010-11]Status: DisposedITAT Delhi19 Nov 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2010-11] Gayatri Sewa Sansthan Vs Dcit 155, G.T.Road, Circle-2(1)(1) Panchwati Ghaziabad, Ghaziabad U.P-201001. Pan-Aaatg1960H Appellant Respondent Appellant By S/Shri Rohit Jain, Adv. Shivam Gupta, Adv. & Deepashree Rao, Adv. Respondent By Shri Manish Gupta, Sr.Dr Date Of Hearing 19.11.2025 Date Of 19.11.2025 Pronouncement

Section 143(3)Section 250

faceless manner, the appellant could not have suo-motu, without specific directions of FAO, produced the representatives of the creditors. Re: Addition u/s 68 of Rs.90,00,000/- qua loan from Baldev Promoters Pvt. Ltd. 2. That the CIT(A) erred on facts and in law in confirming the addition ... erred in not appreciating the crucial fact that the entire loan amount was repaid by the appellant during financial year 2014-15. Re: Addition u/s 68 of Rs.25,00,000/- qua loan from Shri Raju Khan 3. That the CIT(A) erred on facts and in law in confirming

Tikamchand Sahu, Ainthapali vs. Income Tax Officer, Mahasamund

The appeal of the assessee is partly allowed for statistical purposes

ITA 494/RPR/2025[2022-23]Status: DisposedITAT Raipur18 Nov 2025AY 2022-23

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.494/Rpr/2025 िनधा"रण वष" /Assessment Year: 2022-23 Tikamchand Sahu, Ainthapali Imfl Off Shop, Sambalpur, Odisha, 768004 Pan: Hejps3794R .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: None (Adjournment Application)For Respondent: Dr. Priyanka Patel, Sr.DR
Section 143(3)Section 250Section 68

documents on record and have analyzed the facts and circumstances of this case. 9. That regarding the addition u/s 68 of the Act as unexplained cash credit and as per the findings of the Ld. CIT(A)/NFAC, he has simply on summary basis had upheld the findings

Deputy Commissioner of Income Tax, Central Circle 3(2), Kolkata vs. Sincere Commodities and Derivatives Market Pvt. Ltd., Kolkata

In the result, both the captioned appeals of the revenue are dismissed

ITA 1256/KOL/2025[2014-15]Status: DisposedITAT Kolkata18 Nov 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 133(6)Section 143(1)Section 147Section 148Section 250Section 68

judicial pronouncements, we do not find infirmity in the order of the ld. CIT(A) and the same is upheld and the impugned addition u/s 68 is hereby deleted. ITA No.1255/Kol/2025 is accordingly dismissed. ITA No.1256/Kol/2025 - Since the facts and issues involved in 8. both the appeals are identical, therefore

Deputy Commissioner of Income Taxcentral Circle 3(2), Kolkata, Kolakta vs. Sincere Commodities and Derivatives Market Pvt. Ltd., Kolkata

In the result, both the captioned appeals of the revenue are dismissed

ITA 1255/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Nov 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 133(6)Section 143(1)Section 147Section 148Section 250Section 68

judicial pronouncements, we do not find infirmity in the order of the ld. CIT(A) and the same is upheld and the impugned addition u/s 68 is hereby deleted. ITA No.1255/Kol/2025 is accordingly dismissed. ITA No.1256/Kol/2025 - Since the facts and issues involved in 8. both the appeals are identical, therefore

Narendra Shantilal Bapna, Navi Mumbai vs. Income Tax Officer, WD-28(2)(3), Mumbai

In the result, appeal filed by the assessee stands allowed

ITA 4198/MUM/2025[2014-15]Status: DisposedITAT Mumbai18 Nov 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarnarendra Shantilal Bapna V/S. Income Tax Officer, Ward – Flat No. A2501, Plot No. R3 बनाम 28(2)(3) B Emerald Bay, Sector 14, 4Th Floor, Tower No. 6, Vashi Nerul, Navi Mumbai – Station Complex, Vashi, Navi 400 706, Maharashtra Mumbai– 400703, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aclpb8458J Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri Leyaqat Ali Aafaqui, (Sr.DR)
Section 131Section 143(3)Section 68

appeal are as under: 1. On facts and circumstances of the case and in law. Ld. CIT(A) erred in confirming the addition u/s 68 ofRs.2,33,24,050/- of entire sale consideration of STT paid listed shares of M/s Surabhi Chemicals & Investments Ltd on rejecting the appellant’s claim ... passed. Additional Grounds of appeal: 1. On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition u/s 68 of Rs.2,33,24,050/- of entire sale consideration of STT paid listed shares of M/s Surabhi Chemicals & Investments Ltd on rejecting the appellant