“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

Deputy Commissioner of Income Tax, Circle- Agartala, Agartala vs. Rajarshi Motors Pvt. Ltd., Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 121/GTY/2018[2012-13]Status: DisposedITAT Guwahati06 Feb 2025AY 2012-13

Bench: Dr.Manish Borad & Shri Manomohan Dasआयकर अपील सं. / Ita Nos.117 To 123/Gty/2018 िनधा"रण वष" / Assessment Years : 2008-09 To 2014-15 Dcit, Rajarshi Motors Pvt. Ltd., Circle Agartala A.A. Road, Chandrapur, Vs. Agartala, Tripura Pan : Aaccr8033P अपीलाथ" / Appellant ""यथ" / Respondent

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT

Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

section 68" as undisclosed income. Penalty proceedings u/s 271(1)(c) is being separately initiated for furnishing inaccurate details and concealment of income. Addition u/s 68..................................................................Rs. 1,08,26,724/- Undisclosed investment 10. During the course of search and seizure a ledger account of Rajarshi Motor ... section 68 as undisclosed income. Penalty proceedings u/s 271(i)(c) is being separately initiated for furnishing inaccurate details and concealment of income. Addition u/s 68............................................................................Rs. 78,967/- Voluntary Disclosure 11. In course of search proceedings, Shri Swapan Kumar paul, Key person of the Swapan Kumar Paul group disclosed

Deputy Commissioner of Income Tax, Circle- Agartala, Agartala vs. Rajarshi Motors Pvt. Ltd., Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 120/GTY/2018[2011-12]Status: DisposedITAT Guwahati06 Feb 2025AY 2011-12

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT

Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

Deputy Commissioner of Income Tax, Circle- Agartala, Agartala vs. Rajarshi Motors Pvt. Ltd., Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 119/GTY/2018[2010-11]Status: DisposedITAT Guwahati06 Feb 2025AY 2010-11

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT

Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

Deputy Commissioner of Income Tax, Circle- Agartala, Agartala vs. Rajarshi Motors Pvt. Ltd., Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 118/GTY/2018[2009-10]Status: DisposedITAT Guwahati06 Feb 2025AY 2009-10

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT

Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

Deputy Commissioner of Income Tax, Circle- Agartala, Agartala vs. Rajarshi Motors Pvt. Ltd., Agartala

In the result, all the grounds of appeal raised by the Revenue in ITA Nos

ITA 117/GTY/2018[2008-09]Status: DisposedITAT Guwahati06 Feb 2025AY 2008-09

For Appellant: Shri Sanjay Mody, FCAFor Respondent: Shri Kaushik Ray, JCIT

Section 132Section 132(4)Section 142(1)Section 143(2)Section 153A

ITO 19(2)(4), Mumbai vs. Nilesh Pranlal Saglani, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 2059/MUM/2024[2011-12]Status: DisposedITAT Mumbai06 Feb 2025AY 2011-12

Bench: Smt. Beena Pillai (Jm) & Shri Omkareshwar Chidara (Am) Ito-19(2)(4) Nilesh Pranlal Saglani Room No. 507 2/8-10-12, Ground 5Th Floor Vs. Floor, Dadiseth Agiary Piramal Chambers Lane, Kalbadevi Parel, Mumbai Road, Mumbai- 400 012. 400002. Pan : Aayps4855M Appellant Respondent

For Appellant: Shri Asif KarmaliFor Respondent: Shri Rasik Tanna

Section 253Section 68Section 69C

Whether on the facts and the circumstances of the case and in law the Ld. CIT (A) has erred in deleting the addition u/s 68 of the Act of Rs. 1,35,219/ without considering the fact that the Net Worth and the business activity of M/s. Comfort Intech

Income Tax Officer Ward-7(1), Kolkata vs. Tirumala Realcon Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 409/KOL/2024[2012-13]Status: DisposedITAT Kolkata05 Feb 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Tirumala Relcon Private Income Tax Officer, Ward 7(1) Limited Aaykar Bhavan, P-7, 51, Shakespeare Sarani, 2 Nd Chowringhee Square, Vs. Floor,Kolkata-700017, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aadct7159D Assessee By : Shri Siddarth Agarwal, Ar Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 26.11.2024 Date Of Pronouncement : 05.02.2025

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Subhendu Datta, DR

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

However, such non-production of the directors of investing companies alone can never be a basis of suspicion, let alone an addition u/s 68 of the Act. Tirumala Realcon Private Limited; A.Y. 2012-13 9.1. Further, it is a case pertaining to AY 2012- 13, that is before the introduction ... holding that the mere non- appearance/production of directors of assessee company before the ld. AO cannot be a ground for making the addition u/s 68 of the Act. We find support from the decision of Hon’ble Supreme Court in the case of Orissa Corporation Ltd. (supra) “That in this

Raja Ram Choudhary, Malpura vs. Income Tax Officer Ward Tonk, Tonk

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

ITA 1282/JPR/2024[2012-2013]Status: DisposedITAT Jaipur04 Feb 2025AY 2012-2013

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

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-VH

Section 148oSection 250Section 68o

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh

Sree Nagendra Constructions, Khammam vs. DCIT, Circle -2(1), Hyderabad

ITA 198/HYD/2022[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: Shri P Murali Mohan Rao, CA

Section 44ASection 68

Officer. 7. We have considered the rival submissions as well as the relevant material available on record. The Assessing Officer has made the addition u/s 68 of the I.T. Act, 1961 on account of increase in sundry creditors in Para 2 of the assessment order as under ... decisions relied on by the ld.CIT(A) and the ld. DR are concerned, all those decisions relate to addition u/s 68 of the Act where loans or advances have been obtained by the respective assessees and they could not substantiate with evidence to the satisfaction of the AO regarding

M/S. Invorex Trading Pvt. Ltd., Kolkata vs. I.T.O., Ward-7(4), Kolkata

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

ITA 601/KOL/2022[2012-2013]Status: DisposedITAT Kolkata04 Feb 2025AY 2012-2013

Bench: the Id. CIT(A) as well as before us. Secondly, the assessee has miserably failed to establish the three ingredients as prescribed u/s 68 of the Act i.e., identity, creditworthiness of the share subscribers and genuineness of the transactions. Under these given facts and circumstances, we do not find any reason to interfere with the findings of the Ld. CIT(A) in confirming the addition u/s 68 of the Act.” 1.2 Aggrieved with this action, the assessee approached the Hon'ble High Court of Calcu

Section 143(3)Section 250Section 68

given facts and circumstances, we do not find any reason to interfere with the findings of the Ld. CIT(A) in confirming the addition u/s 68 of the Act.” 1.2 Aggrieved with this action, the assessee approached the Hon’ble High Court of Calcutta, where through case No. ITAT/173/2024

Lalita Ramesh Jain, Pune vs. Income Tax Officer, Pradhikaran Pune

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

ITA 1876/PUN/2024[2010-11]Status: DisposedITAT Pune03 Feb 2025AY 2010-11

Bench: SHRI MANISH BORAD (Accountant Member)

For Appellant: NoneFor Respondent: Shri Sanjay Dhivare

Section 147Section 148Section 68Section 69

grievance against the order of Ld. CIT(A)/NFAC :- (i) addition of Rs.27,66,800/- towards unexplained investments u/s 69 and (ii) addition u/s 68 at Rs.5,43,000/- for unexplained credits. 4. Facts in brief are that the assessee is an individual and did not file her return

Shirish Singh Tehra, Nanded vs. Income Tax Officer, Ward 1, Nanded

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2065/PUN/2024[2014-15]Status: DisposedITAT Pune30 Jan 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajesh A. AthavaleFor Respondent: Shri Arvind Desai, Addl CIT DR

Section 147Section 68

Assessing Officer and Ld. CIT(A) / NFAC. It is an admitted fact that due to non-compliance before the Assessing Officer, he made addition u/s 68 of the I.T. Act, 1961 for the above three years being the amount of cash deposited in the bank account maintained with M/s. Shri

Shirish Singh Tehra, Nanded vs. Income Tax Officer, Ward 1, Nanded

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2041/PUN/2024[2016-17]Status: DisposedITAT Pune30 Jan 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajesh A. AthavaleFor Respondent: Shri Arvind Desai, Addl CIT DR

Section 147Section 68

Shirish Singh Tehra, Nanded vs. Income Tax Officer, Ward 1, Nanded

In the result, all the three appeals filed by the assessee are allowed for statistical purposes

ITA 2040/PUN/2024[2015-16]Status: DisposedITAT Pune30 Jan 2025AY 2015-16

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Rajesh A. AthavaleFor Respondent: Shri Arvind Desai, Addl CIT DR

Section 147Section 68

Indraprastha Nagari Sahakari Patsanstha Ltd., Sangli vs. Income-Tax Officer, Ward -5, Sangli

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

ITA 184/PUN/2022[2018-19]Status: DisposedITAT Pune30 Jan 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.184/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Indraprastha Nagari Sahakari Vs. Ito, Ward-5, Sangli. Patsanstha Ltd., Islampur, Walwa, Sangli- 415409. Pan : Aaaai0626B Appellant Respondent Assessee By : Shri Sarang Gudhate Revenue By : Shri Uma Shankar Prasad Date Of Hearing : 21.11.2024 Date Of Pronouncement : 30.01.2025 आदेश / Order Per Vinay Bhamore, Jm: It Is A Recalled Matter. This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.03.2022 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Modified Grounds Of Appeal :- “Ground No. 1: Under The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) / Nfac Is Erred In Disallowing Deduction U/S 80P Of Rs. 65,81,336/-.

For Appellant: Shri Sarang GudhateFor Respondent: Shri Uma Shankar Prasad

Section 143(2)Section 68Section 80PSection 80P(2)(a)Section 80P(2)(d)

Ground No. 2: Under the facts and circumstances of the case and in law, Ld. CIT(A) / NFAC erred in making addition u/s 68 of Rs. 3,57,44,782/-. Ground No. 3: Under the facts and circumstances of the case and in law, Ld. CIT(A) / NFAC erred ... making an addition u/s 68 of Rs. 3,57,44,782/-, whereas same is already considered in Net profit and in gross total income. This addition is resulting as a double taxation. Ground No. 4: The appellant craves the permission to add, amend, modify, revise, substitute, delete or alter any/all

M/S Unihealth Consultancy Limited, Mumbai vs. DCIT, 8 (3) (1), Mumbai

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

ITA 4387/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Jan 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2017-18 M/S Unihealth Consultancy Ltd., The Dy. Cit-8(3)(1), H-13 & H-14 Everest, 9Th Floor, Room No. 615, 6Th Floor, Aayakar Vs. Tardeo Road, Bhavan, Maharishi Karve Road, Mumbai-400034. Mumbai-400020. Pan No. Aabcu 1551 C Appellant Respondent

For Appellant: Ms. Rajeshwari Menon, Sr. DRFor Respondent: Mr. Rajesh Kalyani/ Ajay Dhoot

Section 143(3)Section 68

upheld and the Ground of Appeal of the assessee is rejected. of the assessee is rejected.” 3.1 Regarding the addition u/s 68 of the A Regarding the addition u/s 68 of the Act amounting to ct amounting to Rs.4,20,00,000/- in relation to en in relation to entire ... case including examining the share subscriber examining the share subscribers. Accordingly, we restore the issue . Accordingly, we restore the issue in dispute of addition u/s 68 of the Act to the file of the Assessing addition u/s 68 of the Act to the file of the Assessing addition u/s 68

Kalpana Mishra, Bhubaneswar vs. ITO, Ward 5(4), Bhubaneswar

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

ITA 491/CTK/2024[2016-17]Status: DisposedITAT Cuttack28 Jan 2025AY 2016-17

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अपील संसंसंसं/Ita No.491/Ctk/2024 (िनधा"रण िनधा"रण िनधा"रण वष" िनधा"रण वष" वष" / Assessment Year : 2016-2017) वष" Kalpana Mishra, Vs Ito Ward-5(4), Bhubaneswar Plot No.B-87/A, Chandaka Industrial Estate, Patia, Bhubaneswar-751024 Pan No. :Alfpm 2864 E (अपीलाथ" अपीलाथ" अपीलाथ" /Appellant) अपीलाथ" (""यथ" ""यथ" ""यथ" / Respondent) ""यथ" .. िनधा"रती िनधा"रती क" िनधा"रती िनधा"रती क" क" ओर क" ओर ओर सेसेसेसे /Assessee By ओर : Shri B.R.Pattnaik, Ca राज"व राज"व क" राज"व राज"व क" क" ओर क" ओर ओर सेसेसेसे /Revenue By ओर : Shri S.C.Mohanty, Sr. Dr सुनवाई क" तारीख / Date Of Hearing : 28/01/2025 घोषणा क" तारीख/Date Of Pronouncement : 28/01/2025 आदेश आदेश / O R D E R आदेश आदेश Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 07.03.2024, Passed By The Cit(A), National Faceless Appeal Centre (Nfac), Delhi In Din & Order No.Itba/Nfac/S/250/2023- 24/1062168195(1) For The Assessment Year 2016-2017, On The Following Grounds :- 1. Hon'Ble Cit(Appeals), Nfac Has Erred In Law & On Facts In Confirming The Action Of The Learned Ao Even Though The Learned Ao Has Exceeded His Jurisdiction In A Limited Scrutiny Case Selected Under Cass Only To Examine Whether The Investment & Income Relating To Securities Transactions Are Duly Disclosed Or Not & Added A Sum Of Rs.44,00,000.00 U/S 68 Of The Income Tax Act, 1961, Without Obtaining Prior Administrative Approval Of The Concerned Pr. Cit/Cit As Prescribed In Circular F. No. 225/402/2018/Ita.Ii, Dated 28- 11-2018 & Instruction No.5/2016 [F.No.225/269/2015-

Section 68

learned AO assumed jurisdiction illegally to ask for the source of investment in Kotak Securities Limited and ultimately made an addition u/s 68 in a 'limited scrutiny case. 3.1.36. The appellant would therefore make a prayer for deletion of the addition of Rs.44,00,000.00 made u/s 68 ... learned AO has assumed jurisdiction illegally and made an addition u/s 68, he can't be permitted to legalize it by allowing him to take post facto permission from the competent authority. 3.1.38. The appellant would cite some case decisions in support of her prayer. 3.1.39. In the case

Shiv Vegpro Private Limited, Kota vs. PCIT-Udaipur, Udaipur

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

ITA 1014/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18

For Appellant: Shri Mahendra Gargieya, (Adv.) &For Respondent: Mrs. Alka Gautam, (CIT-DR)

Section 147Section 263Section 36(1)(iii)Section 36(1)(va)Section 43B

appellant filed ROI declaring the same total income. The reassessment was completed after making additions of Rs. 6,93,32,499/- making additions u/s 68 of the Act on account of unexplained credits in the grab of bogus sales and thus, the total income was finally assessed at Rs.16 ... which is treated as an accommodation entry. The Ld. CIT also referred to Para 7 of the subjected assessment order and finally addition u/s 68 of the Act. These admittedly facts that the amount of sales declared by the assessee in the accounts. Thus, the amount subjected to emanated from

Link Commercial Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(4), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1368/KOL/2024[2011-2012]Status: DisposedITAT Kolkata28 Jan 2025AY 2011-2012

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1368/Kol/2024 Assessment Year: 2011-12 Link Commercial Pvt. Ltd...………........………………....Appellant C/O Subash Agarwal & Associates, Advocate Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Aabcl4354L] Vs. Ito, Ward-1(4), Kolkata…….……….…............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Assessee. Shri Pradip Biswas, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : October 30, 2024 Date Of Pronouncing The Order : January 28, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 10.06.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Pertaining To Assessment Year 2011-12. 2. In This Appeal, The Assessee Challenged The Validity Of Reopening Proceedings U/S 147/148 Of The Act & The Addition Of Rs.2,02,00,000/- Made U/S 68 Of The Act As Unexplained Cash Credit. 3. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income On 30.03.2012 By Declaring A Total Income Of Rs.35,061/-. The Return Was Processed U/S 143(1) Of The Act. Subsequent To That, The Case Of The Assessee Was Reopened U/S 147 Of The Act & A Notice U/S 148 Of The Act Was Issued On 31.03.2018 After Obtaining Prior Approval

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

this Tribunal raising multiple grounds. The ld. AR argued that the reopening u/s 147/148 of the Act is invalid and improper as the addition u/s 68 of the Act was erroneous as the transaction with M/s Gokul Commodities Pvt. Ltd. were related to the sale of shares

Lata Agarwal, Bareilly vs. DCIT, Bareilly

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 255/LKW/2023[2014-15]Status: DisposedITAT Lucknow23 Jan 2025AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshralata Agarwal Dcit, Bareilly V. 35-A/6 Rampur Garden Aaykar Bhawan Civil Bareilly-243001, Uttar Pradesh. Lines, Bareilly-243001. Pan:Aanpa0616R (Appellant) (Respondent) Appellant By: Shri Ravinder Aggarwal, Ca Respondent By: Shri. Sanjeev Krishna Sharma, Addl Cit(Dr) Date Of Hearing: 20 01 2025 Date Of Pronouncement: 23 01 2025 O R D E R

For Appellant: Shri Ravinder Aggarwal, CAFor Respondent: Shri. Sanjeev Krishna Sharma, Addl

Section 68

facts by confirming the order passed by the AO in treating the exempted capital gain as unexplained cash credits and thereby making the addition u/s 68 of Rs. 57,00,000/-. 3. On the facts and circumstances of the case, the learned authorities below have erred both on facts