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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

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 1310/KOL/2025[2011-12]Status: DisposedITAT Kolkata27 Oct 2025AY 2011-12

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

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 1309/KOL/2025[2010-11]Status: DisposedITAT Kolkata27 Oct 2025AY 2010-11

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

DCIT, CC-2(1), Kolkata vs. Frankdeal Tracom Pvt Ltd, Kolkata

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

ITA 1308/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

DCIT, CC-2(1), Kolkata vs. Frankdeal Tracom Pvt. Ltd., Kolkata

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

ITA 1307/KOL/2025[2011-12]Status: DisposedITAT Kolkata27 Oct 2025AY 2011-12

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

DCIT, CC-2(1), Kolkata vs. Frankdeal Tracom Pvt Ltd, Kolkata

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

ITA 1290/KOL/2025[2010-11]Status: DisposedITAT Kolkata27 Oct 2025AY 2010-11

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

Rajeev Surana, Mumbai vs. ITO Ward 19(3)(1), Mumbai

ITA 4196/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Oct 2025AY 2018-19

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am Rajeev Surana, Income Tax Officer, Ward 201 Shamiana 67F, Walkeshwar 19(3)(1), Room No. 202, Road, Walkeswar, Matrummandir Tardeo, V Mumbai-400006, Maharashtra Mumbai-400007, S Maharashtra

For Appellant: Shri Aditya SharmaFor Respondent: Shri Annavaran Kosuri, Sr. DR
Section 143(2)Section 143(3)Section 250Section 68

capital was only on account of regrouping of figures of the capital and unsecured loan in two years compared herein and therefore the addition u/s 68 without referring to such documents to correctly analyse the facts of the case was baseless and unjustified. 8. Before

Income Tax Officer, Delhi vs. Megha Garg, Delhi

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

ITA 3488/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Oct 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] Income Tax Officer, Megha Garg, 1707 E-2 Block Civic Centre, 160 Saraswati Vihar Vaishali, New Delhi-110002 Vs Pitampura, Delhi-110034 Pan-Aecpg7098C Appellant Respondent

Section 10(38)Section 147Section 68Section 69A

Counsel submitted that the very fact that ld. AO has invoked the impugned addition is to be made. It was argued that addition u/s 68 was in any case impermissible as the assessee is an individual having no other business income and consequently not maintaining any books of accounts. Reliance

Savegenie E-Marketing Private Limited, Gurgaon vs. ITO, Ward-4(1), Gurgoan

In the result, the appeal of the assessee in ITA No

ITA 3847/DEL/2024[2015-16]Status: DisposedITAT Delhi27 Oct 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Mukesh Mittal, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 139(1)Section 143(3)Section 147Section 148Section 56(2)(vii)Section 68

accepting the valuation report by the competent authority (CA) as prescribed u/s 56(2)(viib) read with Rule 11UA and in making the additions u/s 68 ignoring the Rules and Act. The ld. counsel for the assessee relied upon various judicial decisions as follows: 1. Principal Commissioner of Income ... share premium whereas the facts shows that no addition was made under section 56(2)(viib) and on the other hand upheld the addition u/s 68 without any discussion. 19. With regard to additions u/s 68, the assessee had taken a plea that it is protected by the second proviso

Anjali Gupta, Gurgaon vs. ITO Ward -1(2), Gurgaon

In the result, appeal of the assessee is allowed

ITA 3605/DEL/2019[2015-16]Status: DisposedITAT Delhi27 Oct 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Ms. Anjali Gupta, Ito, Ward-1(2), A-84, Summit, Dlf City-5, Gurgaon, Sector-56, Gurgaon, Vs Haryana Pan-Aaipg5132F Appellant Respondent Assessee By Shri Vijay Kumar Singla, Ca Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 28.07.2025 Date Of Pronouncement 27.10.2025

Section 10(38)Section 115BSection 143(3)Section 68

noting the weak financials of the company, concluded that the impugned company is a penny stock company and proceeded to make the impugned addition u/s 68 r.w.s. 115BE r.w.s. 10(38) of the Act of Rs.48,19,438/- denying the assessee the benefit of Long Term Capital Gains u/s

Kemox Corporation, Bhiwandi vs. DCIT-CC-3, Thane

ITA 221/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Oct 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Ms. Simran Dhawan, Ld. A.RFor Respondent: Shri Ritesh Misra, Ld. D.R
Section 131Section 131(1)(d)Section 142Section 250Section 68

judgment of the Hon'ble Gujarat High Court in the case of CIT Vs. Ayachi Chandrasekhar Narsingi (2024) taxmann.com 250 (Guj.) addition u/s 68 of the Act and interest expenses are not justifiable" ultimately deleted the identical addition. 6. On the contrary, the Ld. D.R. refuted the claim

Deputy Commissioner of Income Tax, Delhi vs. Scan Holdings Private Limited, Delhi

Appeal is dismissed

ITA 3753/DEL/2024[2008-09]Status: DisposedITAT Delhi24 Oct 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2008-09] Dcit, M/S Scan Holdings (P) Ltd., Circle-22(2), Room No.- 225E F-4, Shopping Complex, C.R. Building, I.P. Estate, Vs A-Block, Meera Bagh, New Delhi-110002 Delhi-110087. Pan- Pan- Aabcs0852N Revenue Assessee C.O. No.- 38/Del/2025 Arising Out Of Ita No.3753/Del/2024 [Assessment Year: 2008-09] M/S Scan Holdings (P) Ltd., Dcit, F-4, Shopping Complex, Circle-22(2), Room No.- 225E A-Block, Meera Bagh, Vs C.R. Building, I.P. Estate, Delhi-110087. New Delhi-110002 Pan- Aabcs0852N Assessee Revenue

Section 143(2)Section 143(3)Section 148Section 14A

record, the investment was made in the year 2002 and not in the relevant A.Y. Neither is it an unexplained credit to warrant addition u/s 68. The addition is found to be unwarranted and is deleted forthwith. This ground is allowed.” 6.3 We have heard both the parties and perused

DCIT Central Circle-31, New Delhi vs. Parv Bansal As L/H of Late Anil Kumar Bansal, New Delhi

Accordingly, Ground of appeal No.6 raised by the assessee is partly allowed

ITA 1739/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2012-13] Parv Bansal Vs Dcit L/H Of Late Shri Anil Kumar Central Circle-31 Bansal, 208, 2Nd Floor, S-524 New Delhi Vikas Marg Shakarpur, New Delhi-110092. Pan-Aafpb2542K Appellant Respondent [Assessment Year : 2012-13] Dcit Vs Parv Bansal Central Circle-31 L/H Of Late Shri Anil Kumar New Delhi Bansal, 208, 2Nd Floor, S-524 Vikas Marg Shakarpur, New Delhi-110092. Pan-Aafpb2542K Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv, Shri Deepesh Garg, Adv. Shri Shrey Jain, Adv. & Shri Saksham Agarwal, Ca Revenue By Ms. Pooja Swaroop, Cit Dr & Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 30.07.2025 Date Of Pronouncement 24.10.2025 Order

Section 133ASection 143(2)Section 143(3)Section 154Section 250Section 254Section 68

Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law and on facts in deleting the addition u/s 68 amounting to Rs. 1,96,59,103/-, in respect of unexplained transactions, without verification of the claim of the assessee. 2. Whether

Parv Bansal L/H of Late Sh. Anil Kumar Bansal, New Delhi vs. DCIT Central Circle 31, New Delhi

Accordingly, Ground of appeal No.6 raised by the assessee is partly allowed

ITA 1057/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2012-13] Parv Bansal Vs Dcit L/H Of Late Shri Anil Kumar Central Circle-31 Bansal, 208, 2Nd Floor, S-524 New Delhi Vikas Marg Shakarpur, New Delhi-110092. Pan-Aafpb2542K Appellant Respondent [Assessment Year : 2012-13] Dcit Vs Parv Bansal Central Circle-31 L/H Of Late Shri Anil Kumar New Delhi Bansal, 208, 2Nd Floor, S-524 Vikas Marg Shakarpur, New Delhi-110092. Pan-Aafpb2542K Appellant Respondent Assessee By Dr. Rakesh Gupta, Adv, Shri Deepesh Garg, Adv. Shri Shrey Jain, Adv. & Shri Saksham Agarwal, Ca Revenue By Ms. Pooja Swaroop, Cit Dr & Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 30.07.2025 Date Of Pronouncement 24.10.2025 Order

Section 133ASection 143(2)Section 143(3)Section 154Section 250Section 254Section 68

Whether in the facts and circumstances of the case, the Ld. CIT(A) has erred in law and on facts in deleting the addition u/s 68 amounting to Rs. 1,96,59,103/-, in respect of unexplained transactions, without verification of the claim of the assessee. 2. Whether

M/S. Avanish Orchardes Pvt. Ltd., Chennai vs. ACIT, CC-1(2), Chennai

In the result, the appeals filed by the assessee’s are partly-allowed

ITA 1796/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1791/Chny/2025 िनधा"रण वष"/Assessment Year:2018-19 M/S. Anantram Orchards Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, No.425, 10Th Cross, 18Th Main, Central Circle 1(2), Chennai. Jp Nagar, 2Nd Phase, Jp Nagar, Bangalore – 560 078. Pan: Aaica 8327R (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 1792/Chny/2025 िनधा"रण वष"/Assessment Year:2014-15 M/S. Betelnut Estates Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, (Studio N), Sy No.70, Central Circle 1(2), Chennai. Narne Nagar, Beside Lancohills, Manikonda, Hyderabad – 500 075. Pan: Aafcb 7171D (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Shiva Srinivas, CIT
Section 132Section 153ASection 250Section 68

received in earlier years were converted to preference share capital. It was stated that since no fresh credit was received during the year, addition u/s 68 of the Act cannot be sustained. However, CIT(A) confirmed the addition based on the finding in AY 2019-20 where amount received towards

M/S. Chittaswarup Agro Farming Pvt. Ltd., Chennai vs. ACIT, CC-1(2), Chennai

In the result, the appeals filed by the assessee’s are partly-allowed

ITA 1794/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1791/Chny/2025 िनधा"रण वष"/Assessment Year:2018-19 M/S. Anantram Orchards Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, No.425, 10Th Cross, 18Th Main, Central Circle 1(2), Chennai. Jp Nagar, 2Nd Phase, Jp Nagar, Bangalore – 560 078. Pan: Aaica 8327R (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 1792/Chny/2025 िनधा"रण वष"/Assessment Year:2014-15 M/S. Betelnut Estates Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, (Studio N), Sy No.70, Central Circle 1(2), Chennai. Narne Nagar, Beside Lancohills, Manikonda, Hyderabad – 500 075. Pan: Aafcb 7171D (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Shiva Srinivas, CIT
Section 132Section 153ASection 250Section 68

received in earlier years were converted to preference share capital. It was stated that since no fresh credit was received during the year, addition u/s 68 of the Act cannot be sustained. However, CIT(A) confirmed the addition based on the finding in AY 2019-20 where amount received towards

M/S. Betelnut Estates Pvt. Ltd., Hyderabad vs. ACIT, CC-1(2), Chennai

In the result, the appeals filed by the assessee’s are partly-allowed

ITA 1792/CHNY/2025[2014-15]Status: DisposedITAT Chennai21 Oct 2025AY 2014-15

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1791/Chny/2025 िनधा"रण वष"/Assessment Year:2018-19 M/S. Anantram Orchards Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, No.425, 10Th Cross, 18Th Main, Central Circle 1(2), Chennai. Jp Nagar, 2Nd Phase, Jp Nagar, Bangalore – 560 078. Pan: Aaica 8327R (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 1792/Chny/2025 िनधा"रण वष"/Assessment Year:2014-15 M/S. Betelnut Estates Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, (Studio N), Sy No.70, Central Circle 1(2), Chennai. Narne Nagar, Beside Lancohills, Manikonda, Hyderabad – 500 075. Pan: Aafcb 7171D (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Shiva Srinivas, CIT
Section 132Section 153ASection 250Section 68

received in earlier years were converted to preference share capital. It was stated that since no fresh credit was received during the year, addition u/s 68 of the Act cannot be sustained. However, CIT(A) confirmed the addition based on the finding in AY 2019-20 where amount received towards

M/S. Anantram Orchards Pvt. Ltd., Bangalore vs. ACIT, CC-1(2), Chennai

In the result, the appeals filed by the assessee’s are partly-allowed

ITA 1791/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1791/Chny/2025 िनधा"रण वष"/Assessment Year:2018-19 M/S. Anantram Orchards Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, No.425, 10Th Cross, 18Th Main, Central Circle 1(2), Chennai. Jp Nagar, 2Nd Phase, Jp Nagar, Bangalore – 560 078. Pan: Aaica 8327R (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita No.: 1792/Chny/2025 िनधा"रण वष"/Assessment Year:2014-15 M/S. Betelnut Estates Pvt. The Assistant Commissioner Ltd., Vs. Of Income Tax, (Studio N), Sy No.70, Central Circle 1(2), Chennai. Narne Nagar, Beside Lancohills, Manikonda, Hyderabad – 500 075. Pan: Aafcb 7171D (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Rakesh Joshi, CAFor Respondent: Shri Shiva Srinivas, CIT
Section 132Section 153ASection 250Section 68

received in earlier years were converted to preference share capital. It was stated that since no fresh credit was received during the year, addition u/s 68 of the Act cannot be sustained. However, CIT(A) confirmed the addition based on the finding in AY 2019-20 where amount received towards

Mukesh Kantilal Shah, Mumbai vs. ITO Ward 19(2)(2), Mumbai

Appeal is partly allowed

ITA 811/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Oct 2025AY 2013-14

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

For Appellant: Ms. Dinkle HariyaFor Respondent: Shri Annavaran Kosuri
Section 144Section 144BSection 147Section 68Section 69A

submitted by the Appellant. 6.3. It is submitted that in the facts and the circumstances of the case, and in law, no such addition u/s 68 of the Act was called for. 6.4 Without prejudice to the above, assuming but not admitting that some addition was called

Raj Kumar & Co, Nawanshahr vs. Income Tax Officer, Nawanshahr

In the result, the appeal of the assessee is partly allowed as indicated above

ITA 641/ASR/2024[2017-18]Status: DisposedITAT Amritsar16 Oct 2025AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Ashray Sarna, Adv
Section 115Section 115BSection 144Section 250Section 68

this order, the estimated income has been held to be out of the business of the appellant. The AO had made a separate addition u/s 68 of the Act as unsecured loans of Rs. 43,50,000/- were credited to the balance sheet sources of which were not explained. Creditworthiness ... arise and all deposits in HDFC bank are explained to have come out of sale proceeds of trading business and as such separate additions u/s 68 of the Act , on account of unsecured 16 I.T.A. No. 641/Asr/2024 Assessment Year: 2017-18 loans and partners capital as reflected in draft return

Alka Khandaka, Jaipur vs. Income Tax Officer Ward 1(2), Jaipur

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

ITA 1014/JPR/2025[2017-2018]Status: DisposedITAT Jaipur16 Oct 2025AY 2017-2018

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sauravh Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 131Section 142(1)Section 143(2)Section 143(3)Section 44ASection 68

Jurisdictional ITAT, Jaipur Bench, Jaipur: • Hon’ble Jurisdictional ITAT Jaipur Bench in SHREE DURGA JWELLERS v. ACIT [2025 (5) TMI 116] has held: Addition u/s 68 - cash deposited in the bank account - assessee has not discharged the onus of proving the identity, creditworthiness, and genuineness of the transactions relating ... serviced the decision in the case of Smt. Harshila Chordia [2006 (11) TMI 117 - RAJASTHAN HIGH COURT] in which it was held that “Addition u/s 68 could not be made in respect of the amount which was found to be cash receipts from the customers against which delivery of goods