“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

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

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

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

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

Nathan Anil Rao, Mumbai vs. The ITO -Circle 23(1), Mumbai

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

ITA 8666/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Mar 2026AY 2017-18

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

For Appellant: Shri Vijaykumar Soni, CIT DRFor Respondent: Shri Nikhil Tiwari

Section 143(2)Section 68Section 69

make the not accepted and the Assessing Officer proceeded to make the not accepted and the Assessing Officer proceeded to make the addition u/s 68 of the Act. Being aggrieved, the assessee filed addition u/s 68 of the Act. Being aggrieved, the assessee filed addition u/s 68

Vaneet Aggarwal, New Delhi vs. ACIT, Circle-14(2), New Delhi

In the result, appeal of the Assessee is dismissed

ITA 2607/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 10(38)Section 143(1)Section 143(2)Section 69ASection 69C

ITA No. 2607/Del/2019 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F': NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT

Shri. Shanthisagar Co Op Credit Society Limited, Hubli vs. Income Tax Officer, Ward-2(1), Hubli

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

ITA 2081/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Mar 2026AY 2017-18

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

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

books of account, it was held that when Assessee already admitted sale proceeds as revenue receipts . Therefore there is no case of addition u/s 68" 20.3 We also find support from the decisions of coordinate benches of the Tribunal in Sri Tatiparti Satyanarayana((ITA No. 76/Viz/2021, dated March ... Govt. of India dated 08.11.2016 the assessee was not authorised to accept cash deposits in SBNs and the AO had made addition u/s. 68. We note that the assessee has filed details of cash deposits from members in their accounts with society along with KYC details and assessee has discharged

ACIT Circle-1(1), Rajkot vs. Grenic Tiles Pvt Ltd, Morbi

The appeal of the assessee is allowed, whereas

ITA 682/RJT/2025[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 624/Rjt/2025

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 133(6)Section 143(3)Section 250Section 68

Rajasthan High Court in the case of Smt. Harshila Chordia vs ITO (2008) 298 ITR 349 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

Grenic Tiles Private Limited, Wankaner-Morbi vs. Asst.Commissioner of Income-Tax Circle 1(1) RKT, Rajkot

The appeal of the assessee is allowed, whereas

ITA 624/RJT/2025[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 624/Rjt/2025

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR

Section 133(6)Section 143(3)Section 250Section 68

Suresha Chikkajala Ramakrishnappa, Bangalore vs. DCIT, Central Circle-2(3), Bangalore

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

ITA 1292/BANG/2025[2021-22]Status: DisposedITAT Bangalore11 Mar 2026AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

For Appellant: Shri V Srinivasan , AdvocateFor Respondent: Shri Subramanian, JCIT (DR)

Section 250Section 68

difference in balance and not in respect of the opening balance brought forward from earlier years. It is a settled position that an addition u/s 68 of the Act cannot be made in respect of an opening balance carried forward from the preceding year. In these circumstances, we find

Piyush Ashok Mehta, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9092/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Mar 2026AY 2010-11

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora

Section 133ASection 143(1)Section 143(3)Section 147

could not point out any deficiency in the information and explanations furnished by the assessee. Hence, there is no reason for making addition u/s 68 of the Act and accordingly, we are of the view that the learned CIT(A) was justified in deleting the additions made u/s 68

Piyush Ashok Mehta, Mumbai vs. DCIT, Central Circle 6(4), Mumbai

Accordingly, Ground No. 2 raised by the Assessee in the present appeal in allowed

ITA 9091/MUM/2025[2009-10]Status: DisposedITAT Mumbai11 Mar 2026AY 2009-10

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI BIJAYANANDA PRUSETH (Accountant Member)

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Ms. Deepika Arora

Section 133ASection 143(1)Section 143(3)Section 147

ACIT, Delhi vs. Jagpreet & Co, Delhi

In the result, the appeal of the revenue is dismissed

ITA 4890/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshacit, Vs. Jagpreet & Co, 1704, E2, Block Civic 17/124, Subhash Nagar, Centre, New Delhi Delhi (Appellant) (Respondent) Pan: Aahfj2561L Assessee By : Shri K. Sampath, Adv Shri V. Raja Kumar, Adv Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 27/01/2026 Date Of Pronouncement 11/03/2026

For Appellant: Shri K. Sampath, AdvFor Respondent: Shri Om Prakash, Sr. DR

Section 143(3)Section 68

cash received from debtors etc. The ld AO however did not agree with the contentions of the assessee and proceeded to make addition u/s 68 of the Act of ₹2,97,30,000/- on account Jagpreet & Co of cash deposits made during the demonetization period as unexplained cash credit u/s

Worldwide Textiles Private Limited, Delhi vs. ACIT, Circle-27(2), Delhi

In the result, the appeal of the assessee is allowed

ITA 4855/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri M. Balaganeshworldwide Textiles Pvt. Ltd, Vs. Acit, D-12/49, 1St Floor, Sector-7, Circle-27(2), Rohini, Delhi Delhi (Appellant) (Respondent) Pan: Aabcw4900B

For Appellant: Shri J. S. Kochar, CAFor Respondent: Shri Om Prakash, Sr DR

Section 133(6)Section 143(3)Section 68

notice u/s 133(6) of the Act. Thereafter the ld AO proceeded to disagree with the contentions of the assessee and made addition u/s 68 of the Act of ₹31,91,000/- on account of cash deposits made during the demonetization period as unexplained cash credit u/s 68 r.w.s. 115BBE

East Delhi Leasing P.Ltd, New Delhi vs. ITO, Ward-8(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 7917/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Mar 2026AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 147Section 148

reason for escapement of income for the reason that the assessee rotated the funds within the group and proceeded to make the addition u/s 68 for issue of share application money even though the assessee had submitted the relevant documents. The reasons recorded and addition made

ITO, New Delhi vs. M/S. Wisdom Export Pvt. Ltd., Delhi

In the result, the appeal of the Revenue is dismissed

ITA 2172/DEL/2017[2007-08]Status: DisposedITAT Delhi11 Mar 2026AY 2007-08

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2007-08]

Section 143(3)Section 68

raised following grounds of appeal:- On the facts and in the circumstances of the case and in law the order deleting the addition u/s 68 of the I TAct by not appreciating the proposition that relief can be allowed only after completing the fact finding process as held ... fact and circumstances of the case the Ld. CIT Appeal was erred in deleting the addition of Rs. 3 Crore made on account addition u/s 68 of the IT Act without appreciating facts that the assessee failed to explain the same in his books of account during the course

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1592/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh10 Mar 2026AY 2019-20

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1230/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1592/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2019-20) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 10.03.2026 : आदेश / O R D E R Per Bench 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2019-20Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals)-3

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –

Section 115BSection 132Section 153A(1)(b)Section 153DSection 65BSection 68

case of Sh. Agarsen Logistic (ITA No. 108/Agra/2025 dated 24-06-2025) has been rendered on identical facts. The Agra Tribunal held that addition u/s 68 could not be made on preponderance of probability and there has to be some evidence to establish the fact of unexplained cash credit

Saraf the Jewellers, Chandigarh vs. The Deputy/Assistant Commissioner of Income Tax Cen-2 Chandigarh, Chandigarh

Appeal stand dismissed

ITA 1230/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh10 Mar 2026AY 2019-20

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –

Section 115BSection 132Section 153A(1)(b)Section 153DSection 65BSection 68

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

assessment was completed u/s 147 r.w.s. 144B on 23.03.2022 determining total income at Rs. 1,223,91,15,486/- by making addition u/s 68 of the Act. 4. Aggrieved by the order of the Assessing Officer, the assessee filed appeal before the Ld. CIT(A). The Ld. CIT(A) upheld

Prodigy Infomatics Private Limited, Mumbai vs. ITO, 15(2)(4), Mumbai

Accordingly, these grounds are dismissed

ITA 2124/MUM/2025[2012-13]Status: DisposedITAT Mumbai10 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Jagadishprodigy Infomatics Private Vs. Ito, 15(2)(4), Mumbai Limited Director Ito, 15(2)(4), Mumbai Plot No. D- 388, Midc, Ttc Aayakar Bhavan Industrial Area, Kukshet Mumbai- 400020 Village, Navi Mumbai - 400705 Pan/Gir No. Aadcp3211A (Applicant) (Respondent) Assessee By None Revenue By Shri Virabhadra Mahajan, (Sr. Dr) Date Of Hearing 04.03.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 18.02.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2012-13. The Following Grounds Are Reproduced Below: “1. On The Facts & In The Circumstances Of The Case & In Law, The Learned C.I.T. (A) Erred In Dismissing The Appeal.

Section 250Section 68

such a short period. But, the A.O. has not made any Inquiry and conveniently treated all the loan amount with interest as addition u/s 68 of the Act. Even the basic fact in two cases where the amounts got squared up through banking channel also not appreciated by A.O. properly

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)

ITAT, Chennai Bench. 6. We have carefully considered all the relevant facts of the case. It is evident that the AO made the addition u/s 68 of the Act without negating any of the evidences adduced by the assessee to demonstrate the genuineness of the impugned transaction. None of them

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3647/DEL/2025[2021-22]Status: DisposedITAT Delhi09 Mar 2026AY 2021-22

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

substantiated soft data/ excel sheets, is bad in law and is liable to be quashed. Page 3 of 26 ITA Nos.3643 to 3647/Del/2025 Addition u/s 68 of the Income Tax Act, 1961 not attracted 7. That on the facts and in the circumstances of the case

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle - 13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3646/DEL/2025[2020-21]Status: DisposedITAT Delhi09 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B

Jsp Projects (P) Ltd, Delhi vs. DCIT Central Circle -13, Delhi

In the result appeal of the assessee in ITA number 3646/Del/2025 and

ITA 3645/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Mar 2026AY 2019-20

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shukla, Accountnat Member

Section 127(2)Section 153ASection 153CSection 63Section 65B