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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

Accord Electropower Private Limited, Noida vs. ITO, Ward 5 (1)(1), Noida

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

ITA 5411/DEL/2024[2018-19]Status: DisposedITAT Delhi09 Feb 2026AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

Section 143(3)Section 250Section 68

Electropower Pvt Ltd Noida 2.1 Briefly stated, the genuineness and creditworthiness of these shareholders were not proved, therefore, Ld. AO made the impugned addition u/s 68 in the hands of the assessee. During appellate proceedings, additional evidences were submitted by the assessee, in respect of which a remand report

Ved Infra, Dehgam vs. Income-Tax Officer, Ward-2 Gandhinagar, Gandhinagar

In the result, ground no. 3 raised by the assessee is devoid of merits and liable to be dismissed

ITA 1773/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad06 Feb 2026AY 2023-24

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)

Therefore, the creditworthiness and genuineness in this case has not been proved. Accordingly, I am of the view that AO has rightly made addition u/s 68 of the Act. Ground No.3 of the appeal is dismissed. ………………………….. The appellant firm has earned book profit before remuneration to partner

ACIT, New Delhi vs. Arjun Enterprises Private Limited, Mumbai

In the result, ground No.5 & 6 raised by the revenue are dismissed

ITA 4257/DEL/2025[2018-19]Status: DisposedITAT Delhi06 Feb 2026AY 2018-19

Bench: Satbeer Singh Godara & Shri S. Rifaur Rahmanacit , Vs. Arjun Enterprises Pvt. Ltd. New Delhi 711, Filix Commercial Complex, Opp Asian Paints L.Bs Marg Bhandup W Mumbai 400078 Maharashtra (Pan: Aahca 1448 A)

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR
Section 133(6)Section 143(2)Section 40Section 68

ascertained as the assessee has failed to submit the confirmation from the creditors. With the above observation he proceeded to make the addition u/s 68 of the Act. Further he observed that assessee has incurred financial cost in the form of interest of Rs.3,65,16,322/- for meeting

ACIT, New Delhi vs. Nouvelle Securities Pvt Ltd, Delhi

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

ITA 4852/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Manoj Tiwari, Sr. DR
Section 132Section 132(4)Section 153ASection 37Section 68Section 69C

facts and in the circumstances of the case and in law, the learned CIT(A) ought to have deleted on merits the addition u/s 68 by appreciating that the respondent had duly discharged its onus u/s Page 3 of 12 CO No. 21/DEL/2025 [A.Y. 2016-17] Nouvelle Securities 68

Income Tax Officer, New Delhi vs. Sukam Jewellers Pvt Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 4040/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2017-18]

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

within time period of 4 hours after declaration of demonetization at 8:00 PM on 08.11.2016. Accordingly, the AO made addition u/s 68 of the Income Tax Act, 1961. Aggrieved by the impugned assessment order the appellant is in present appeal. 4. Per Contra, ld. DR relied upon the order

Income Tax Officer, Ward-43(1), Delhi, New Delhi vs. Vinod Kumar Kansal, Main Tota Ram Bazar, Trinagar

In the result, the appeal of the revenue is dismissed

ITA 3519/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanito, Vs. Vinod Kumar Kansal, Ward-43(1), 2722/203, Main Tota Ram New Delhi Bazar, Trinagar, Delhi (Appellant) (Respondent) Pan: Akapk5817H

For Appellant: Shri S. Kraishanan, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(3)Section 68

Vinod Kumar Kansal 4. The ld AO, however, did not agree with this contention and proceeded to make addition u/s 68 of the Act of Rs 1,54,95,500/- on account of cash deposits. The ld AO noticed that assessee had indeed shown cash sales and held that merely

DCIT, New Delhi vs. Prudential Hotels Pvt. Ltd., Delhi

In the result both the grounds raised by the revenue are dismissed

ITA 2936/DEL/2024[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

For Appellant: NoneFor Respondent: Sh. Ajay Kumar Arora, Sr. DR
Section 143(2)

No.2936/Del/2024 includes income u/s 68 of I.T. Act, penalty proceedings u/s 271AAC of the Income Tax Act. 1961 are being initiated separately. (Addition u/s 68 of the Act: 7,70,00,000/-) Tax is to be charged u/s 115BBE of the Act in respect of the addition made u/s 68

Sukhbir Singh, Guruharsahai vs. Income Tax Officer Ward-3(1), Ferozepur

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

ITA 28/ASR/2025[2018-19]Status: DisposedITAT Amritsar04 Feb 2026AY 2018-19

Bench: Shri Manoj Kumar Aggarwal & Shri Udayan Dasguptaआयकर अपील सं./ Ita No. 28/Asr/2025 "नधा"रण वष" / Assessment Year: 2018-19 Sukhbir Singh, Ito, C/O Sukhbir Singh & Co., V Ward 3(1), Faridkot Road, S Ferozepur Guruharsahai, Punjab 152022 "थायी लेखा सं./Pan No: Ahjps2687M अपीलाथ"/Appellant ""यथ"/Respondent Virtual Hearing

For Appellant: NoneFor Respondent: Sh. Charan Dass, Sr. DR
Section 143(3)Section 250Section 68

agricultural income as authentic and disallowed an amount of Rs. 92 lakhs (approx.) as income from sources other than agriculture, resulting in an addition u/s 68 of the Act, in absence of adequate documentary evidences pertaining to sale proceeds of such quantity of agricultural produce as declared and also

Deputy Commisioner of Income Tax Circle 3(1)(1) Ahmedabad, Ahmebabad vs. Techno Industries, Ahmedabad

In the result, the appeal filed by the Revenue is partly allowed

ITA 660/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyaltechno Industries, Deputy Commissioner Of Vs. Plot No. 613, Phase Iv, Income-Tax, Gidc, Vatva, Circle 3(1)(1), Ahmedabad-382 245 Ahmedabad [Pan : Aacft 1503 D] (Appellant) .. (Respondent) Assessee By : Shri Bandish Soparkar, Ar Respondent By: Shri Abhijit, Sr Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:- This Appeal Has Been Filed By The Revenue Against The Order Dated 22.01.2025 Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (“Ld. Cit(A)” For Short), Under Section 250 Of The Income-Tax Act, 1961 (“The Act” For Short), Relating To The Assessment Year 2017- 18. 2. The Revenue Has Raised Following Grounds Of Appeal :- “(1) The Ld. Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs 1,03,00,000/- Made By Ao On Account Of Unsecured Loan Received From Various Lenders U/S. 68 Of It Act, Despite The Fact That The Assessee Had Not Corroborative Evidences Identity Genuineness/Creditworthiness Of The Lenders During Assessment Establish The Proceedings. (2) The Ld. Cit(A) Has Erred In Law & On Facts In Admitting The Additional Evidences During Appellate Proceedings, Without Giving The Opportunity To The Ao As Required By Rule 46A.. (3) The Ld. Cita) Has Erred In Law & On Facts In Deleting The Addition Of Rs.1,66,037/- Made By Ao On Account Of Disallowance Of Interest On Unsecured Loans Paid To Lenders, Despite The Fact That The Assessee Had Not Dcit Vs. Techno Industries Asst. Year : 2017-18 - 2–

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, Sr DR
Section 143(3)Section 250Section 36(1)(va)Section 68

deleted the above additions. Against the said relief, the Revenue is in appeal before us. Ground No. 1 & 2 – Addition u/s 68 and Rule 46A 5. The Assessing Officer made an addition of Rs.1,03,00,000/- u/s 68 in respect of unsecured loans received from five parties, holding that ... Revenue to controvert these factual findings. 5.4 In view of the settled law that once identity, creditworthiness and genuineness are established, no addition u/s 68 can be sustained and we, therefore, find no infirmity in the order of the Ld. CIT(A). Accordingly, Ground Nos. 1 and 2 raised

N N Sippy Productions Pvt Ltd, Mumbai vs. ITO Ward 13(1)(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 4961/MUM/2025[2020-21]Status: DisposedITAT Mumbai03 Feb 2026AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarn.N. Sippy Productions V/S. Income Tax Officer – 13(1)(1) Private Limited बनाम 225, Aaykar Bhavan, M.K. A4, Shalimar Chs, Road, Mumbai – 400 054, Santacruz, Mumbai – Maharashtra 400054, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aagcn6412N Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Mehul Talera, ARFor Respondent: Shri Leyaqat Ali Aafaqui, (Sr. DR)
Section 133ASection 147Section 250Section 68

turnover as per GST records. Therefore, the actual nature of the credit entry could not be established by the assessee leading to its addition u/s 68 of the Act. 7. We have carefully considered all the relevant facts of the case, heard rival submission and also perused the records

Anirudh Daga, Mumbai vs. ITO 23(10(6), Mumbai

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

ITA 2176/MUM/2024[2012-13]Status: DisposedITAT Mumbai03 Feb 2026AY 2012-13

Bench: The Itat

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

Bimalchand Jain 39 Taxman.com 196, held that where abnormal price rise in a share not in consonance with company fundamentals was there, then addition u/s 68 can be made. 7.7. But, the adjudication order filed by Ld. DR before ITAT was not available to the Department or Assessee

Mr. Anmol Govindram Sekhri, Bandra Arcade, Nandi Gully, Opp Bandra Railway St vs. Circle 16(2), Mumbai, Aayakar Bhawan

In the result, appeal of the assessee is allowed

ITA 1091/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Feb 2026AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarmrs. Suneeta Sekhri V/S. Deputy Commissioner Of (Legal Heir Of Mr. Anmol बनाम Income Tax, Circle – 16(2), Govindram Sekhri), Aayakar Bhavan, Mumbai – Ground Floor, Bandra Arcade, 400020, Maharashtra Nandi Gully, Opp. Bandra Railway Station, Bandra(West), Mumbai – 400 050, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Alhps9957L Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Aditya Ajgaonkar & Ms. Rupal Shrimal, ARsFor Respondent: Shri Rajesh Kumar Yadav, (CIT-DR)
Section 144BSection 147Section 263Section 68

made u/s 68 of the Act. Therefore, it was clear that no revision could be made u/s 263 of the Act by making addition u/s 68 of the Act when the first appellate authority itself had held that no case for section 68 disallowance is made out. This also shows

DCIT - CC -3(2), Mumbai vs. Mangalkalash Trading Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is allowed

ITA 576/MUM/2019[2012-13]Status: DisposedITAT Mumbai02 Feb 2026AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: NoneFor Respondent: Mr. Pankaj Kumar, CIT-DR
Section 132Section 132(4)Section 143(1)Section 143(3)Section 153ASection 68Section 69Section 69C

totally aggregating to Rs 5,90,00,000/- from concerns of Pravin Kumar Jain. The AO has made the substantive additions u/s 68 in the hands of M/s First Winner Textiles P Ltd., M/s Bhagwat Textiles P_Ltd., M/s Starwood Exports P Ltd., M/s Rikosh Fashions ... part of the said order is from Para 6.3.1 to 6.3.26 at pages 13 to 24. In the said appellate order, the substantive additions u/s 68 made of Rs 7,00,00,000/- Mangalkalash Trading P. Ltd. 5 ITA No. 576/MUM/2019 have been confirmed which includes the addition related

Manishbhai Ramesbhai Bhut, Rajkot vs. Income Tax Officer, Rajkot

ITA 318/RJT/2025[2017-18]Status: DisposedITAT Rajkot30 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 115BSection 133(6)Section 142(1)Section 143Section 143(2)Section 144Section 68Section 69A

quashed and justice be done; Dff Manishbhai R.Bhut 2.0 The learned assessing officer has erred in law and on facts in making addition u/s 68 r.w.s. 115BBE of the Act of Rs. 32,86,000/-, as alleged income from undisclosed sources, which may kindly be deleted and justice be done

Bhaveshbharthi Ghanshyambharthi Goswami, Surat vs. ITO Ward 3(1)(2), Surat

In the result, the appeal of the assessee is allowed

ITA 436/SRT/2025[2010-11]Status: HeardITAT Surat30 Jan 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 143(3)Section 148Section 250Section 68

during the year under consideration. It is also an undisputed fact that the assessee did not maintain any books of account, and the addition u/s 68 of the Act has been made solely based on entries in the bank statements. The assessee has furnished a plausible explanation that the deposits

Mahtab Chand Agarwal, Lucknow vs. DCIT-6, Lucknow

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

ITA 515/LKW/2024[2017-18]Status: DisposedITAT Lucknow30 Jan 2026AY 2017-18

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2017-18 Mahtab Chand Agarwal, V. The Dcit-6 15, Ajanta Market, Near P.K. Complex, Ram Gurdwara, Nishatganj, Mohan Rai Marg, Lucknow-226010. Lucknow-208001. Pan:Aeipa6452N (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri R. R. N. Shukla, Addl. Cit- Dr Date Of Hearing: 04 11 2025 Date Of Pronouncement: 30 01 2026 O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri R. R. N. Shukla, Addl. CIT- DR
Section 115BSection 142(1)Section 143(3)Section 250Section 68

came to the conclusion that the amounts deposited in the bank account could not have arisen out of sales and, accordingly, made an addition u/s 68 of the Act. The Ld. Sr. Departmental Representative therefore submitted that no interference was called for in the order passed by the lower authorities

Jitendra Nanasaheb Thorat, Nashik vs. Income Tax Officer, Ward 2(4), Nashik

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

ITA 2307/PUN/2025[2011-12]Status: DisposedITAT Pune30 Jan 2026AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2307/Pun/2025 निर्धारण वषा / Assessment Year: 2011-12 Jitendra Nanasaheb Thorat, V Income Tax Officer, A-7, Chaitrapalavi Apartment, S Ward-2(4), Nashik. Ashok Marg, Near Bank Of Maharashtra, Behind Fame Cinema, Nashik – 422006. Pan: Afypt8886Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Through Virtual) Revenue By Shri Ajitesh Kumar Meema –Addl.Cit Date Of Hearing 29/01/2026 Date Of Pronouncement 30/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2011-12 Dated 28.07.2023 Emanating From The Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Act, Dated 27.12.2017. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250Section 68

this case being dismissed by the Hon'ble Supreme Court. 2 ITA No.2307/PUN/2025 [A] 6] The learned CIT(A) erred in confirming the addition u/s 68 of Rs.21,78,500 made by the A.O. by holding that the entire cash deposits made in bank accounts of the appellant

Laxmikant Nandkishor Toshniwal, Latur vs. ITO, Ward-1, Latur

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

ITA 1853/PUN/2024[2016-17]Status: DisposedITAT Pune30 Jan 2026AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1853/Pun/2024 िनधा"रण वष" / Assessment Year : 2016-17 Laxmikant Nandkishor Vs. Ito, Ward-1, Latur. Toshniwal, Nandkishor Toshniwal, Deva Niwas, Bhagya Nagar, Nandi Stop, Latur- 413512. Pan : Agppt1081M Appellant Respondent Assessee By : Shri Shubham N. Rathi (Virtual) Revenue By : Shri Amol Khairnar Date Of Hearing 05.01.2026 : Date Of Pronouncement 30.01.2026 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2016-17. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. Non-Acceptance Of Condonation Of Delay 1.1 The Learned Commissioner Of Income Tax(Appeals) ["The Ld. Cit(A)] Has Erred In Not Condoning The Delay In Filing Of The Appeal Without Properly Considering The Cause For Delay.

For Appellant: Shri Shubham N. Rathi (Virtual)For Respondent: Shri Amol Khairnar
Section 142(1)Section 147Section 148Section 68

present case no provisions of section 68 of the Act are attracted. 3.4 In the above facts and circumstances and in law, the addition u/s 68 of the Act is not warranted and deserves to be deleted. 4. ADDITION OF ₹ 38,59,45,371/- U/S 68 ... present case no provisions of section 68 of the Act are attracted. 4.4 In the above facts and circumstances and in law, the addition u/s 68 of the Act is not at all warranted and deserves to be deleted. 5. LIBERTY The Appellant craves leave to add, alter, amend

Gunai Shikshan Prasarak Mandal, Udgir vs. Deputy Commissioner of Income-Tax, Aurangabad

In the result, the appeal filed by the assessee in ITA

ITA 1421/PUN/2025[2017-18]Status: DisposedITAT Pune29 Jan 2026AY 2017-18

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Tanaji Chavan
Section 115BSection 143(3)Section 68

donors and genuineness of the transactions could be established. Accordingly, the grounds of appeal on this issue is hereby dismissed. 6.3 Ground No.2 – Addition u/s 68 of the Act - Rs.80,18,423/- 6.3.1 It is observed from the assessment order, the appellant has made cash deposits of Rs.80

Deputy Commissioner of Income Tax, Exemptions Circle, Aurangabad vs. Gunai Shikshan Prasarak Mandal, Latur

In the result, the appeal filed by the assessee in ITA

ITA 1370/PUN/2025[2017-18]Status: DisposedITAT Pune29 Jan 2026AY 2017-18

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Tanaji Chavan
Section 115BSection 143(3)Section 68

donors and genuineness of the transactions could be established. Accordingly, the grounds of appeal on this issue is hereby dismissed. 6.3 Ground No.2 – Addition u/s 68 of the Act - Rs.80,18,423/- 6.3.1 It is observed from the assessment order, the appellant has made cash deposits of Rs.80