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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

Shri V. Natarajan (Individual), Rasipuram vs. ACIT, Central Circle, Salem

In the result, both the appeals of assessee in ITA No

ITA 1801/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Oct 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

return for A.Y. 2015-16 was also filed after the date of search. The additions made, including Disallowance of interest Rs.8,93,642/-, Addition u/s 68 of Rs.10,65,970 and Rs.50,50,000/-, Addition of Rs.24,80,636/- (marriage gifts) and Disallowance of LTCG improvement cost Rs.50 lakhs ... P.Patel Vs ITO, ITA 92/Ahd/2020, ITAT Ahmedabad held that mere receipt of amount via banking channel doesn't make the transaction as genuine. Addition u/s 68 of the Income Tax Act sustainable because of non-establishment of identity of creditor, genuineness of transaction and credit worthiness of the parties

Varadappan Natarajan, Rasipuram vs. ACIT, Central Circle, Salem

In the result, both the appeals of assessee in ITA No

ITA 1535/CHNY/2024[2016-17]Status: DisposedITAT Chennai31 Oct 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

return for A.Y. 2015-16 was also filed after the date of search. The additions made, including Disallowance of interest Rs.8,93,642/-, Addition u/s 68 of Rs.10,65,970 and Rs.50,50,000/-, Addition of Rs.24,80,636/- (marriage gifts) and Disallowance of LTCG improvement cost Rs.50 lakhs ... P.Patel Vs ITO, ITA 92/Ahd/2020, ITAT Ahmedabad held that mere receipt of amount via banking channel doesn't make the transaction as genuine. Addition u/s 68 of the Income Tax Act sustainable because of non-establishment of identity of creditor, genuineness of transaction and credit worthiness of the parties

Kambar Constructions, Mumbai vs. ITO WD-25(2)(5), Mumbai

In the result, the appeal filed by the assessee is hereby allowed for statistical purpose

ITA 5357/MUM/2025[2013-14]Status: DisposedITAT Mumbai31 Oct 2025AY 2013-14

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm Kambar Constructions Income Tax Officer Ward – A-52, Dakshina Park, N. S. Road No. 25(2)(5), Mumbai. Vs. 10, Juhu Scheme, Mumbai – 400049. Pan/Gir No. Aakfk6879M (Appellant) (Respondent) :

For Appellant: Shri Neelam JadhavFor Respondent: Shri Hemanshu Joshi, SR DR
Section 250Section 68

principle of natural justice is violated. The order of the Learned NFAC (A) may be quashed and set aside. II. Merits: Addition u/s 68 as Unsecured Loans Rs.1,26,26,848/- 4. The Learned NFAC (A) erred in sustaining the addition of Rs.1,26,26,848/- on account of unsecured

Baby Kunwar Jhala, Neemuch vs. Deputy Commissioner of Income-Tax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 87/JODH/2024[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

order of the Commissioner of Income Tax (A), Udaipur-2 (hereinafter referred to "the CIT(A)] even dated 22/11/2023, challenging therein confirmation of addition u/s 68 of the Income Tax Act (In short 'the act'). 2. All the appellants have raised common grounds of appeal except minor variation ... quantum of addition u/s 68 of the act and therefore, all these appeals were heard together and adjudicated by the consolidated order for the sake of convenience and brevity. The facts of the case are discussed from ITA No. ITA No. 338/Jodh/2024 as a lead case for discussion and adjudication

Pushkar Nagda, Kanakheda vs. Dy Commissioner of Incometax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 352/JODH/2024[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

order of the Commissioner of Income Tax (A), Udaipur-2 (hereinafter referred to "the CIT(A)] even dated 22/11/2023, challenging therein confirmation of addition u/s 68 of the Income Tax Act (In short 'the act'). 2. All the appellants have raised common grounds of appeal except minor variation ... quantum of addition u/s 68 of the act and therefore, all these appeals were heard together and adjudicated by the consolidated order for the sake of convenience and brevity. The facts of the case are discussed from ITA No. ITA No. 338/Jodh/2024 as a lead case for discussion and adjudication

Bherulal Nagda, Kanakheda vs. Dy Commission of Income-Tax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 351/JODH/2024[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

order of the Commissioner of Income Tax (A), Udaipur-2 (hereinafter referred to "the CIT(A)] even dated 22/11/2023, challenging therein confirmation of addition u/s 68 of the Income Tax Act (In short 'the act'). 2. All the appellants have raised common grounds of appeal except minor variation ... quantum of addition u/s 68 of the act and therefore, all these appeals were heard together and adjudicated by the consolidated order for the sake of convenience and brevity. The facts of the case are discussed from ITA No. ITA No. 338/Jodh/2024 as a lead case for discussion and adjudication

Gayatri Sharma, Kelukheda Teh. Choti Sadri vs. Dy. Commissioner of Income-Tax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 338/JODH/2024[2012-13]Status: DisposedITAT Jodhpur30 Oct 2025AY 2012-13

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

order of the Commissioner of Income Tax (A), Udaipur-2 (hereinafter referred to "the CIT(A)] even dated 22/11/2023, challenging therein confirmation of addition u/s 68 of the Income Tax Act (In short 'the act'). 2. All the appellants have raised common grounds of appeal except minor variation ... quantum of addition u/s 68 of the act and therefore, all these appeals were heard together and adjudicated by the consolidated order for the sake of convenience and brevity. The facts of the case are discussed from ITA No. ITA No. 338/Jodh/2024 as a lead case for discussion and adjudication

Gayatri Sharma, Neemuch vs. Dy. Commissioner of Income-Tax, Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 337/JODH/2024[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

order of the Commissioner of Income Tax (A), Udaipur-2 (hereinafter referred to "the CIT(A)] even dated 22/11/2023, challenging therein confirmation of addition u/s 68 of the Income Tax Act (In short 'the act'). 2. All the appellants have raised common grounds of appeal except minor variation ... quantum of addition u/s 68 of the act and therefore, all these appeals were heard together and adjudicated by the consolidated order for the sake of convenience and brevity. The facts of the case are discussed from ITA No. ITA No. 338/Jodh/2024 as a lead case for discussion and adjudication

Ram Chandra Anil Kumar Goyak HUF, Geetayan vs. Commissioner of Income-Tax (Appeals), Income-Tax Office Udaipur

In the result, the appeals of the assesses in ITA Nos

ITA 468/JODH/2023[2010-11]Status: DisposedITAT Jodhpur30 Oct 2025AY 2010-11

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 148Section 68

order of the Commissioner of Income Tax (A), Udaipur-2 (hereinafter referred to "the CIT(A)] even dated 22/11/2023, challenging therein confirmation of addition u/s 68 of the Income Tax Act (In short 'the act'). 2. All the appellants have raised common grounds of appeal except minor variation ... quantum of addition u/s 68 of the act and therefore, all these appeals were heard together and adjudicated by the consolidated order for the sake of convenience and brevity. The facts of the case are discussed from ITA No. ITA No. 338/Jodh/2024 as a lead case for discussion and adjudication

Rupesh Kumar Mittal, Jaipur vs. ITO WD 7(1), Jaipur

In the result, the appeal of the assessee is allowed

ITA 971/JPR/2025[2021-22]Status: DisposedITAT Jaipur30 Oct 2025AY 2021-22

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shailesh Mantri, C.AFor Respondent: Shri. Gautam Singh choudhary, JCIT
Section 250Section 68

considered this amount of Rs. 29 Lacs (Loan received from Mother and sister) as unexplained and made the addition u/s 68 of the Income tax Act. 3. This whole amount was received from banking channel both mother and sister of the assessee are having PAN and regularly filing there return ... amount can not be deemed to be income of the assessee, without any cogent evidence brought on record by the AO and thus, addition u/s 68 by him cannot be sustained. Additionally, as discussed above, the assessee's burden is confined to prove identity of the creditors, creditworthiness of creditor

M/S. Midnapur Timber Traders, West Midnapur vs. ITO, NFAC, Delhi

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

ITA 1616/KOL/2025[2022-2023]Status: DisposedITAT Kolkata30 Oct 2025AY 2022-2023

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 145(3)Section 250Section 68

computed the profit by applying percentage on the turnover of the appellant and as such no separate addition u/s 68 could have been made and in view of the facts and in the circumstances it may be held accordingly. 6. For that your petitioner craves the right to put additional

Income Tax Officer, Ward-7(2)(3), Bengaluru vs. Mohammed Farooq Kanana, Bengaluru

In the result, appeal filed by the Revenue is dismissed

ITA 1509/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Oct 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri.Soundararajan Kassessment Year : 2020-21 Ito, Vs. Mr. Mohammed Farooq Kanana, 6 9Th Cross, H Siddaiah Road, Ward – 7(2)(3), Bangalore. Bangalore – 560 027, Karnataka. Pan : Abvpm 1212 A Appellant Respondent Assessee By : Shri. Thirumala Naidu, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 27.10.2025 Date Of Pronouncement : 30.10.2025

For Appellant: Shri. Thirumala Naidu, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 147Section 250

under. Accordingly, he deleted the addition made by the AO: Page 9 of 15 “5.5. As established, the quintessential points for any addition u/s 68 of the I T Act are identity and credit worthiness of the party and genuineness of the transaction. In the instant case, as seen from

Kbj Developers Pvt Ltd, Mumbai vs. Asst Commisioner of Income Tax- 4(2)(1), Mumbai

ITA 1837/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Oct 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 133(6)Section 142Section 143(1)Section 143(2)Section 250

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

Assistant Commissioner of Income Tax - Circle-4(2)(1), Mumbai vs. Kbj Developers Private Limited, Mumbai

In the result, appeal filed by the Revenue is dismissed and

ITA 1409/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 Oct 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry

For Respondent: Shri Satyaprakash Singh, Ld. CA
Section 133(6)Section 142Section 143(1)Section 143(2)Section 250

Even otherwise, simply on the reason that investor has low income as compared to investment made, is no ground for making the addition u/s 68 of the Act as there is no requirement under the law that Investor has to make the investment out of income only. For the purpose ... observed above that simply on the reason that investor has low income as compared to investment made, is no ground for making the addition u/s 68 of the Act as there is no requirement under the law that Investor has to make the investment out of income only

Deputy Commissioner of Income Tax, Delhi vs. La Solitaire Jewels Private Limited, Delhi

The Appeal of the Revenue is dismissed

ITA 181/DEL/2024[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishradeputy Commissioner Of Vs La Solitaire Jewels Income Tax, Private Limited Room No. 316A, C. R. 2706, Bank Street Road, Building, I. P. Estate, Karol Bagh, New Delhi- New Delhi 110005 Delhi Pan: Aaacl9483H Appellant Respondent Assessee By Sh. Mayankpatwari, Adv & Sh. Akashojha, Adv Revenue By Sh. Gouranga Chandra, Sr. Dr Date Of Hearing 27/08/2025 Date Of Pronouncement 30/10/2025

Section 143(2)Section 143(3)Section 145Section 145(3)Section 68

Grounds of Appeal are as under:- “1 Whether on the facts and circumstances of the case the Ld. CIT(A) erred in deleting addition u/s 68 related to cash deposits representing cash sales of Rs. 8,39,,36,867/- as explained even though it was 1349% increase as compared ... cash sale and their deposit in the bank account consequent to demonization could not be basis for the rejection of account and addition u/s 68 of the Act. The Tribunal Bench at Vishakhapatnam in the case of Asstt. CIT v. HirapannaJewellers [2021] 128 taxmann.com 291/189 ITD 608 held as under

Edakkalathur Devassy Daiz, Thrissur vs. ACIT, Circle-2(1), Thrissur

In the result, appeal of the assessee bearing ITA

ITA 651/COCH/2025[2017-18]Status: DisposedITAT Cochin29 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Edakkalathur Devassy Daiz .......... Appellant Edakkalathur House, Ayyanthole P.O. Thriussur 680003 [Pan: Abppd1785R] Vs. Acit, Circle 2(1), Thrissur ......... Respondent Assessee By: Ms. Krishna K., Advocate Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: Ms. Krishna K., AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 250Section 68

argument stated that the Ld AO without giving any proposals for addition or with issuance show-cause notice made the addition U/s 68 of the Act. The aggrieved assessee filed appeal before the Ld. CIT(A). Finally, the appeal order was also passed exparte. Having considered the totality of facts

Janta Land Promoters Pvt Ltd, Mohali vs. The Prinicipal Commissioner of Income Tax, Chandigarh-1, Chandigarh

In the result, appeal of the Assessee is allowed

ITA 618/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-2021
For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 194Section 263Section 68

customers Rs.64,285.60 lakh and Advance against property Rs.7,607.14 lakh; (iv) Rs.921.39 lakh “previous year taxes” appearing in Reserves & Surplus, proposed for addition u/s 68; and (v) alleged non-review of Transfer Pricing / MAT. 3. The Ld. AR had submitted that pursuant to the show cause notice issued

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva
Section 132(1)Section 147Section 148Section 151Section 68

name of the assessee was mentioned. Based on the said information, the assessee’s case was reopened wherein, the Ld. AO made an addition u/s 68 of the Act amounting to Rs.2,58,67,123/- vide order dated 30.12.2017 passed u/s 147 r.w.s. 143(3) of the Act. Before ... bogus interest expenses towards the loans which are nothing but accommodation entries. Further, the said loans being accommodation entries are subject matter of addition u/s 68 of the Act in the instant case which has been confirmed by the ld. CIT(A) in the appellate order. 13 ITA No.1656/PUN/2024

ACIT, New Delhi vs. Vrinda Farms Private Limited, New Delhi

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

cash has been exchanged against any specific loan taken by appellant. Based on the above mentioned reasons, ld. CIT(A) held that the addition u/s 68 of Rs.590 Lakhs made by AO shall be deleted. He further relied on various decisions relied upon to prove that no addition

DCIT, CC-2(1), Kolkata vs. Amanat Trade Comm Pvt Ltd, Kolkata

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

ITA 1311/KOL/2025[2012-13]Status: DisposedITAT Kolkata27 Oct 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1290, 1307 & 1308/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Frankdeal Tradcom Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aabcf1099A] Ita Nos.1309, 1310 & 1311/Kol/2025 Assessment Years: 2010-11, 2011-12 & 2012-13 Dcit, Cc-2(1), Kolkata.…………………………………………….…….……Appellant Vs. Amanat Trade Comm Pvt. Ltd..………………………...………...……...…..…..Respondent 6D, Shyamkunj, 12C Lord Sinha Road, Kol- 7. [Pan: Aagca3278H] Appearances By: Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Miraj D Shah, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2010-11, 2011-12 & 2012-13 Against Separate Orders Of The Commissioner Of Income Tax (Appeals)-26, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Search Operation, Therefore, These Appeals Have Been Heard Together & Are

Section 132Section 139(1)Section 143(1)Section 143(2)Section 153ASection 250Section 68Section 69C

153A r.w.s. 143(3) of the Act on 27.09.2021 on a total income of Rs.5,37,56,220/- after making following additions: 1. Addition u/s 68 of the Act Rs. 5,36,20,000/- 2. Addition u/s 69C of the Act Rs. 1,34,050/- 3. Aggrieved by the said