“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

Sanganeriya Spinning Mills Ltd, Gurgaon vs. DCIT, Circle-23(2), Delhi

In the result, the appeal of the assessee is allowed

ITA 2157/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Feb 2026AY 2017-18

Bench: Shri Mahavir Singh, Hon’Ble

Section 143(3)Section 250Section 68

transaction had been duly discharged by the assessee. In view of the settled legal position in this regard, we hold that no addition u/s 68 could be made in the hands of the assessee, in the absence of any further inquiry by the Ld. AO to conclude that the impugned

Jitendra Kumar Agarwal HUF, Agra vs. DCIT, Circle - 2(1)(1), Agra

In the result, assessee’s appeal is allowed

ITA 454/AGR/2025[2017-18]Status: DisposedITAT Agra16 Feb 2026AY 2017-18

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 115BSection 143(1)Section 143(2)Section 143(3)Section 250Section 68

books of account are accepted as correct and complete, individual entries therein cannot be selectively disbelieved on mere suspicion or conjecture. The addition u/s. 68 of the Act has been made solely on the basis of a comparison of cash-sale figures of earlier months and an assumption that ... completed the assessment with the belief that all the cash sales relevant for cash deposits are non-genuine and proceeded to make the addition u/s 68 of the Act. The Assessing Officer had not even bothered to give opportunity to the assessee to report such negative findings by the Inspector

M/S Shivansh Infraestate Pvt.Ltd., Lucknow vs. Dy. CIT Range-6, Lucknow

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

ITA 106/LKW/2024[2015-16]Status: DisposedITAT Lucknow13 Feb 2026AY 2015-16

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2015-16 M/S Shivansh Infraestate Pvt. Ltd., Vs. The Deputy Commissioner Of 3Rd Floor, Block-A, Surajdeep Income Tax, Range-6, 3Rd Floor, Complex, 1-Jopling Road, 27/2, Raja Ram Mohan Rai Marg, Lucknow-226001 P.K. Complex, Lucknow Pan: Aaqcs5896P (Appellant) (Respondent) Assessee By: Sh. Shubham Rastogi, C.A. Revenue By: Sh. Neeraj Kumar, Cit Dr Date Of Hearing: 20.11.2025 Date Of Pronouncement: 13.02.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Passed Under Section 250 Of The Income Tax Act, 1961 On 18.01.2024 Wherein The Ld. Cit(A) Has Partly Allowed The Appeals Of The Assessee Against The Orders Of The Ld. Assessing Officer Dated 30.12.2017. The Grounds Of Appeal Are As Under:- “1- The Ld. Cit (A) Nfac Erred On Facts & In Law In Dismissing The Ground That Notice U/S 143(2) Was Issued By Ito-6(1) Lucknow On 01.04.2016 Without Appreciating That Jurisdiction Of Case Lies With Dcit, Range-6, Lucknow, Hence The Notice Issued By Ito-6(1) Is Without Jurisdiction & Invalid. Further, No Notice U/S 143(2) Has Been Issued By Jurisdictional Dcit, Range-Vi, Lucknow Within The Period As Per Section 143(2) Of L. T. Act. Hence The Present Assessment Is Invalid, Bad In Law & Liable To Be Quashed. 2- The Ld. C.I.T. (A) Upheld The Addition Without Appreciating That Ld. A. O. Rejected The Books Of Account & Instead Of Estimating The Net Profit, Additions Were Made On The Basis Of Same Books Of Account By Disallowing Expenses Under Different Heads Total Rs. 1,75,91,607/- & Addition U/S 68 R. W. S. 115Bbe Of I. T. Act For Rs. 1,32,78,833/- Which Is Contrary To The Provisions Of Law.

For Appellant: Sh. Shubham Rastogi, C.AFor Respondent: Sh. Neeraj Kumar, CIT DR

Section 143(2)Section 145(3)Section 250Section 68

were made on the basis of same books of account by disallowing expenses under different heads total Rs. 1,75,91,607/- and addition u/s 68 r. w. s. 115BBE of I. T. Act for Rs. 1,32,78,833/- which is contrary to the Provisions

M/S. Kalptaru Cotton Industries, Mehsana vs. The ITO, Ward-5 Now Ward-1, Patan

In the result, the appeal of the assessee is allowed

ITA 1545/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad13 Feb 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Adjournment application filedFor Respondent: Shri Kamal Deep Singh, Sr DR

Section 143(2)Section 143(3)Section 250Section 44ASection 68

Officer and the Ld. CIT(A) and submitted that the assessee failed to satisfactorily prove the creditworthiness of the lender and therefore the addition u/s 68 was rightly sustained. 9. We have carefully considered the orders of the Assessing Officer and the Ld. CIT(A), the Statement of Facts

M/S Stance Consumer Electronics Private Limited, Delhi vs. Deputy Commissioner of Income Tax, CC-32, Delhi

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2792/DEL/2025[2017-18]Status: DisposedITAT Delhi13 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

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

received from the sale of shares of M/s Prominent Agency Pvt. Ltd. to M/s Vandam Technologies Private Limited as unexplained credits and made addition u/s 68 of the Act. Accordingly, the total income of the assessee was assessed at Rs.1,58,10,662/-. The AO further made protective addition ... short term capital gains with the observation that it will become substantive addition in case addition u/s 68 is deleted by the appellate authorities. 14. Against the said order, assessee filed appeal before the Ld. CIT(A) who vide order dated 29.03.2025, has partly allowed the appeal of the assessee

M/S Stance Consumer Electronics Private Limited, New Delhi vs. Deputy Commissioner of Income Tax, CC-32, Delhi

In the result appeal of the assessee for AY 2017-18 in ITA No

ITA 2791/DEL/2025[2016-17]Status: DisposedITAT Delhi13 Feb 2026AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.2791 & 2792/Del/2025 (Assessment Yearss 2016-17 & 2017-18)

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

Mkf International, Mumbai vs. DCIT Circle 17(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 7726/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Feb 2026AY 2018-19

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmkf International Dcit Circle 17(1), 1903/1905, Aarus Wing, Kautilya Bhavan, Wallace Fortuna, Shivdas Vs. Bkc, Mumbai – Chapsi Marg, Opp-Fazlani 400 051 School, Chinchbunder Ho, Mumbai-400 009 Pan/Gir No. Abhfm5244N (Applicant) (Respondent) Assessee By Shri Dharmesh Shah A/W Ms. Mitali Parekh, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 10.02.2026 Date Of Pronouncement 12.02.2026

Section 115BSection 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 270ASection 68

before us raising following grounds of appeal: 1. The Ld. CIT(A) NFAC has erred in law and in facts in upholding the addition u/s 68 of the Act amounting to Rs. 19.06.08.525/- in respect of the capital contribution made by all the partners. 2. The appellant craves leave

Prabhulal Kalji Doshi, Mumbai vs. ITO Ward 19(2)(4), Mumbai

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

ITA 7421/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

Section 143(3)Section 148Section 148ASection 151Section 68

Assessment Year: 2017-18 and the income escapement is below 50 lacs, i.e. Rs.28,86,000/-, therefore reopening is bad in law. II. Addition u/s 68 of Rs. 28,86,000/-: 5. The Id. CIT (A) erred in confirming the addition made by AO of Rs.28

Bharatkumar Gadodia, Mumbai vs. ACIT Circle 31(1)(1), Mumbai

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

ITA 6362/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ajay R. Singh,Adv & Akshay Pawar, AdvFor Respondent: Shri Leyaqat Ali Aafaqui (Sr. Ar.)

Section 10(38)Section 143(3)Section 250

present case also, we note that, the revenue has not been able to establish any of the requirements to justify the addition u/s 68 of the Act. We, therefore, do not find it fit to confirm the addition made by the Ld.AO. Accordingly, the additions made in relation to transactions

Sree Narayana Guru Cooperative Thrift and Credit Society Limited, Dwarka Delhi vs. ITO 43(6), New Delhi

ITA 5165/DEL/2025[2017-18]Status: DisposedITAT Delhi12 Feb 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Ankush Kalra, SR.DR

Section 142(1)Section 143(2)Section 147Section 148

raised by the assessee with the following observations:- 5.1 On perusal of the assessment order it was observed that the AO made the addition u/s 68 of the Act since the identity and creditworthiness of the depositors not established. Further appellant has claimed that that the details of all members

Sree Narayana Guru Cooperative and Credit Society Limited, Dwarka Delhi vs. ITO 43(6), New Delhi

ITA 5164/DEL/2025[2012-13]Status: DisposedITAT Delhi12 Feb 2026AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Ankush Kalra, SR.DR

Section 142(1)Section 143(2)Section 147Section 148

ACIT, Circle-7(1), Delhi vs. Eberspaecher Suetrak Bus Climate Control Systems India Private Limited, Delhi

Appeal is dismissed as premature

ITA 3665/DEL/2025[2014-15]Status: DisposedITAT Delhi12 Feb 2026AY 2014-15

Bench: Shri.Rifaur Rahman & Shri Vimal Kumar

Section 133(6)Section 142(1)Section 143(2)Section 144Section 68

held that mere non response to notice u/s 133(6) of the Income Tax Act by a creditor cannot be basis of addition u/s 68 of Income Tax Act. The relevant part of the judgement of the Hon'ble Jurisdictional High Court is reproduced as under: 15. In our view

ACIT, C 2(1)(1), Agra vs. Sunil Kumar Joshan, Agra

In the result, the appeal of the revenue is dismissed and cross objection of the assessee is dismissed as infructuous

ITA 494/AGR/2025[2014-15]Status: DisposedITAT Agra11 Feb 2026AY 2014-15

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singhacit, Vs. Sunil Kumar Joshan, Foot On Shoes, 7Th Circle-2(1)(1), Agra Km Stone, Agra Delhi Bye Pass Road, Agra (Appellant) (Respondent) Pan: Abqpj4015P Co 07/Agr/2025 (In Ita No.494/Agr/2025) (Assessment Year: 2014-15) Sunil Kumar Joshan, Vs. Acit, Foot On Shoes, 7Th Km Circle-2(1)(1), Stone, Agra Delhi Bye Agra Pass Road, Agra (Appellant) (Respondent) Pan: Abqpj4015P

For Appellant: Shri Sahib P. Satsangi, CAFor Respondent: Shri Sukesh Kumar Jain, CIT DR

Section 143(3)Section 68

claimed as gross receipts from exhibition sale of paintings at CO 07/AGR/2025 Sunil Kumar Joshan Singapore. Accordingly, the addition u/s 68 is found to be unjustified and is deleted. 5.3 Ground 10 is with regard to claim of deduction u/s 80G. 9. On going through the aforesaid elaborate documentary evidences

Vardaan Infrastructures Private Limited, Raipur vs. Income Tax Officer, Ward 4(1), Raipur

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

ITA 834/RPR/2025[2013-14]Status: DisposedITAT Raipur11 Feb 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 834/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14) Vardaan Infrastructures Private Limited, Vs Income Tax Officer, Ward 4(1), C/S Shankar Marbles, Ring Road 1, Ayakar Bhawan, Civil Lines, Santoshi Nagar, Raipur, Chhattisgarh, Raipur, Chhattisgarh, 492001 Pan: Aadcv3823C (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Praveen Khandelwal & Shri Praveen Goyal, Cas राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 09/02/2026 घोषणा की तारीख / Date Of : 11/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2013-14 Filed By The Assessee Is Directed Against The Order Dated 06.11.2025 Of Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri Praveen Khandelwal and Shri Praveen Goyal, CAsFor Respondent: Dr. Priyanka Patel, Sr. DR

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

capital gain. 7. That on the facts and in the circumstances of the case and in law, the assessing officer erred in making addition u/s 68 of the Act of Re. 2,19,14,303/- on account of share application money and unsecured loan. 8. The appellant craves

Savera Commotrade Private Limited, Kolkata vs. ITO, Ward 5(3), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1719/KOL/2025[2009-2010]Status: DisposedITAT Kolkata10 Feb 2026AY 2009-2010

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

For Appellant: Shri Akkal Dudhwewala, ARFor Respondent: Shri V Vidhyadhar, DR

Section 131Section 133(6)Section 142(1)Section 143(1)Section 147Section 263Section 68

documents placed on record, the Hon’ble High Court dismissed the Revenue’s appeal and upheld the order of this Tribunal deleting the addition u/s 68 by observing as under: "....ZJt is not in dispute that the assessee had filed complete details of each of the shares to prove

DCIT - 19(1), Mumbai, Lalbaugh vs. Bharat Ramji Bhai Manek, Grant Road Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 4339/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Leyaqat Ali Aafaqui, (SR DR)

Section 10(38)Section 143(3)Section 250

rejected LTCG exemption u/s 10(38) for penny stock gains, holding that suspicion based on modus operandi and lack of economic rationale justifies addition u/s 68, adding Rs. 84.79 lakh as unexplained credit. Other Relevant: The Hon'ble Calcutta High Court in Pr. CIT v. Swati Bajaj emphasized that

Decent Securities P Ltd, Delhi vs. ACIT, Circle- 7(1), Delhi

In the result, appeal of the assessee is dismissed

ITA 6472/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Feb 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 143(3)Section 250Section 263Section 68

already Page | 2 ITA No.6472/Del/2025 on record, was convinced in respect of 15 loan parties and hence, chose not to make any addition u/s 68 of the Act. Hence, the Id AO, on appreciation of factual evidences available on record had taken a plausible view on the matter of examination

Hasmukh Ugarchand Gadhecha, HUF, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

The appeal of the assessee stands allowed

ITA 591/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

For Appellant: Shri Deepak R. Shah, ARFor Respondent: Shri Hargovind Singh, Sr.DR

Section 10(38)Section 143(3)Section 147Section 148Section 153CSection 250Section 68Section 69C

case in not allowing an opportunity of cross examination of persons whose statements were relied upon and personal hearing before confirming addition U/S 68 of the Act 6. Your appellant craves for leave to add, amend or alter all or any of the grounds before or during hearing of this

Choksi Ranchhodlal Kishordas, Ahmedabad vs. The Pr. CIT, Ahmedabad-1, Ahmedabad

In the result, appeal filed by the assessee is allowed

ITA 558/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad09 Feb 2026AY 2013-14

Bench: us, A.Y. 2013-14, in the case of the assessee. According to the Ld. PCIT, the reasons for which the case of the assessee was reopened was not properly inquired into by the AO and, therefore, the assessment order, according to him, was erroneous causing prejudice to the Revenue for not having made any addition on account of income which was believed to have escaped assessment in the case of the assessee. The reopening, it transpires, was resorted to on finding that the assessee had received

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri Rignesh Das, CIT.DR

Section 143(3)Section 147Section 263

erred in not verifying the transportation receipts etc, so as to prove the genuineness of sales. The A.O. has failed to make addition u/s 68 of the Act despite the society being entry provider. The order of the A.O. is therefore treated as erroneous in so far as prejudicial

Nova Elevators Private Limited, Mumbai vs. ITO-13(1)(1), Mumbai

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

ITA 7248/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Feb 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokarnova Elevators Private Vs Ito -13(1)(1), Mumbai Limited Maharashtra-400020 402, Dimple Apts., 4E, Asha Nagar, Kandivali East, Mumbai-400101 Pan: Aadcn0305K Appellant Respondent Assessee By : Shri Sharad Patel, Ca Respondent By : Shri Leyaqat Ali Aafaqui, (Sr Ar) Date Of Hearing : 29/01/2026 Date Of Pronouncement : 09/02/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-51, Mumbai [For Brevity ‘The Ld. Cit(A)], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2014-15, Date Of Order 12.09.2025. The Impugned Order Emanated From The Order Of The Ld. Income-Tax Officer Ward-13(1)(1), Mumbai

For Appellant: Shri Sharad Patel, CAFor Respondent: Shri Leyaqat Ali Aafaqui, (SR AR)

Section 133(6)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

taken the following grounds & additional grounds: “1. Misapplication of Section 68-Failure to Apply Settled Onus Framework The CIT(A) erred in sustaining addition u/s 68 despite the assessee having discharged the primary onus by proving the identity, credit-worthiness, and genuineness of the lender through bank-routed transactions, response