“identity of creditor”

Cash Credits & Unexplained ItemsSection 68Section 68515 judgments

The decision most relied on for identity of creditor is CIT v. Orissa Corporation Pvt. Ltd. (159 ITR 78), cited in 897 judgments on BharatTax.

Leading authorities on identity of creditor

CIT v. Orissa Corporation Pvt. Ltd.

159 ITR 78 · 1986 · Supreme Court

897

citing judgments

When an assessee provides the identity and address of a creditor or investor for a cash credit or share capital under Section 68, the burden shifts to the Department to establish lack of genuineness or creditworthiness, requiring it to conduct further inquiries; mere non-compliance by third parties to summons cannot be the sole basis for an adverse inference against the assessee.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

DCIT v. Rohini Builders

256 ITR 360 · 2002 · High Court

489

citing judgments

An assessee discharges the initial onus under Section 68 for cash credits by providing creditor details like PAN and addresses, proving creditworthiness via banking transactions, and demonstrating genuineness, especially when loans are repaid through cheques.

Roshan Di Hatti v. CIT

107 ITR 938 · 1977 · Supreme Court

477

citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.

208 ITR 465 · 1994 · High Court

427

citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

CIT v. Divine Leasing & Finance Ltd.

299 ITR 268 · 2008 · High Court

426

citing judgments

An assessee introducing share capital or share premium must establish the identity, genuineness of the transaction, and creditworthiness of the immediate investor or creditor; the burden does not extend to proving the 'source of source' or the financial capacity of the investor's sub-creditors.

Nemi Chand Kothari v. CIT

264 ITR 254 · 2003 · High Court

340

citing judgments

For a cash credit, merely transacting by cheque is insufficient to discharge the assessee's burden of proof. The assessee must prove the identity of the creditors, the genuineness of the transaction, and the creditworthiness of the creditors; upon which, the burden shifts to the revenue.

CIT v. Gagandeep Infrastructure (P.) Ltd.

394 ITR 680 · 2017 · High Court

303

citing judgments

Under Section 68, an assessee is only required to prove the identity and creditworthiness of the immediate creditor or share subscriber and the genuineness of the transaction. The assessee is not obligated to establish the 'source of the source' of funds or the creditworthiness of sub-lenders, as this information may not be within the assessee's special knowledge.

Judgments citing identity of creditor

Sastvijay Investment & Consultancy Services P.Ltd, New Delhi vs. ITO, Ward-22(4), New Delhi

In the result, both the appeals filed by the assessee are allowed

ITA 901/DEL/2019[2010-11]Status: DisposedITAT Delhi10 Nov 2021AY 2010-11

Bench: Shri R.K. Panda & Shri Vijay Pal Rao

For Appellant: Shri Amol Sinha &For Respondent: Shri Prakash Dubey, Sr. DR

Section 132Section 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 68

light of above, it has to be seen that to what extent, appellant has been able to satisfy all three conditions, i.e., identity of creditor, creditworthiness and genuineness of transactions in its case. So far as the word 'identity' is concerned, Hon'ble jurisdictional High Court in the case ... channels in the shape of share application money. In view of above, it is clear that the appellant has failed to establish the identity of creditors in its case. Thus, the first condition as stipulated in section 68 of the Act is not satisfied. 8.4 As regards the other conditions

Geeta Bhasin, Noida vs. JCIT, Range- 32, New Delhi

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

ITA 4600/DEL/2017[2011-12]Status: DisposedITAT Delhi09 Nov 2021AY 2011-12

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi(Through Video Conferencing) Geeta Bhasin, Vs. Jcit, C/O. Sandeep Sapra, Adv, C-763, Range-32, New Friends Colony, New Delhi New Delhi Pan: Acdpb6005D (Appellant) (Respondent)

For Appellant: Shri Sandeep Sapra, AdvFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143Section 2Section 68Section 69A

back by him. Therefore, learned assessing officer treated the above sum as an unexplained credit as the assessee has failed to establish the identity of creditor and the creditworthiness of the creditor and the genuineness of the transaction. The learned assessing officer further noted that while making an attempt

A.C.I.T., Circle-49(1), Kolkata vs. M/S Viswakarma Residency, Kolkata

Appeal is dismissed

ITA 255/KOL/2020[2016-17]Status: DisposedITAT Kolkata26 Oct 2021AY 2016-17

Bench: Shri Sanjay Garg & Dr. M.L.Meenaआयकर अपील सं.य/ Assessment Years:2016-17 बनाम / Acit, Cir-49(1), Kolkata M/S. Viswakarma Residency Uttarpan Complex, Ds-Iv, V/S. 2Nd Fl., Manicktala Civick Centre, Block-2 & 3, 2Nd Fl., Kolkata-700 054. Pan: Aaifv3279Q अपीलाथ" /Appellant ""यथ" /Respondent .. Hearing Through Video Conferencing अपीलाथ" क" ओर से/By Appellant Shri Manish Kanojia, Cit, Dr ""यथ" क" ओर से/By Respondent Shri S.M Surana, Advocate, Ar सुनवाई क" तार"ख/Date Of Hearing 04-08-2021 घोषणा क" तार"ख/Date Of Pronouncement 26-10-2021

Section 131Section 133(6)

justified-Held, yes. f. Commissioner of Incometax, AhmedabadIV v. Sachitel Communications (P) Ltd. [2014] 51 taxmann.com 205(Gujarat). Where assessee proved identity of creditor, its capacity and further transaction, was made through bank, any addition as unexplained unsecured loans would be unsustainable. g. Commissioner of IncometaxII, Indore v. Vaibhav Cotton

ACIT, Circle - 35, Kolkata vs. M/S. Machinery Agencies India, Kolkata

ITA 2100/KOL/2018[2014-15]Status: DisposedITAT Kolkata30 Sept 2021AY 2014-15

Bench: Shri P. M. Jagtap(Kz) & Shri A. T. Varkey]

Section 131Section 68Section 69C

creditor from the assessee. [Para 19] M/s Machinery Agencies India., AY 2014-15 In the instant case, the assessee had established the identity of creditors, namely, N and 'P'. The assessee had also shown, in accordance with the burden, which rested on him under section 106 of the Indian Evidence

Dy CIT 15(1)(2), Mumbai vs. M/S Leena Poower Tech Engineers P Ltd., Navi Mumbai

In the result, the appeal is allowed

ITA 1313/MUM/2020[2011-12]Status: DisposedITAT Mumbai21 Sept 2021AY 2011-12

Bench: Us Is A Private Limited Company Stated To Be Engaged In The Business As 'Investment Company' In Column 10, Page 1, Of The Impugned Assessment Order. Its Assessment Under Section 143(3)

Section 143(3)Section 68

Calcutta High Court has held that under the scheme of Section 68 "it was necessary for the assessee to prove prima facie the identity of creditors, the capacity of such creditors and lastly the genuineness of transactions". Similarly, in the case of CIT v. Precision Finance ... observed that "it is for the assessee to prove the identity of creditors, their creditworthiness and genuineness of transactions". It is thus also a settled legal position that the onus of the assessee, of explaining nature and source of credit, does not get discharged merely by filing confirmatory letters

DCIT Circle- 6 (3)(2), Mumbai vs. M/S Jostar Orgotech Pvt Ltd, Mumbai

ITA 103/MUM/2020[2012-13]Status: DisposedITAT Mumbai03 Sept 2021AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No. 103/Mum/2020 (धििाारण वर्ा / Assessment Year: 2012-13) Dcit-(6)(3)(2) M/S Jostar Orgotech Pvt. Ltd. बिाम/ Aaykar Bhavan, R. No. 576 A-501, Innova Marathon Next Gen. M.K. Road, Mumbai-400 020. Off. Ganpatrao Kadam Marg Vs. Lower Parel(W), Mumbai-400 008 स्थायीलेखासं./ जीआइआरसं./ Pan/Gir No. Aabcj-2496-H (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Revenue By : Ms. Usha Gaikwad– Ld. Sr. Dr Assessee By : Shri J. P. Bairagra– Ld. Ar सुनवाई की तारीख/ : 30/08/2021 Date Of Hearing घोषणा की तारीख / : 03/09/2021 Date Of Pronouncement आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2012-13 Arises Out Of The Order Of Learned Commissioner Of Income-Tax (Appeals)-12, Mumbai [Cit(A)], Dated 02/09/2019 In The Matter Of Assessment Framed By Ld. Assessing Officer U/S 143(3) On 28/03/2015. The Sole Ground By The Revenue Read As Under: - On The Facts & Circumstances Of The Case & In Law, The Ld.Cit(A) Erred In Deleting The Addition Of Rs.5,68,60,000/- Made By The Ao On Account Of Share Application Money/Share Capital & Share Premium Which Is Held As Unexplained

For Appellant: Shri J. P. Bairagra– Ld. ARFor Respondent: Ms. Usha Gaikwad– Ld. Sr. DR

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

assessee to establish the identity and the credit worthiness of the creditor as well as the genuineness of transaction. 5. The identity of creditors can be established by furnishing their PANs or assessment orders. The genuineness of the transaction can be proved if it was shown that the money

Swarn Gems P Ltd., New Delhi vs. ITO, New Delhi

Appeal of the assessee is allowed

ITA 473/DEL/2014[2007-08]Status: DisposedITAT Delhi04 Aug 2021AY 2007-08

Bench: Ms Suchitra Kamble & Shri Prashant Maharishi

Section 133(6)Section 68

which was not at all disputed in the Remand Report by the Assessing Officer. Thus, the assessee established genuineness of all the transactions, identity of creditors and the source of the fund received. As regards to Ground No. 3 relating to credit balance in current account of ICICI Bank ... creditors and the advances obtain was a genuine loan from the customers. Hence, the assessee has establish genuineness of all the transactions, identity of creditors and source of the funds received. The Assessing Officer has totally ignored all these facts while filing the remand report on the contrary

M/S Swargamrut Dairy Prv Ltd, Mumbai vs. DCIT 11 (2)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 6839/MUM/2019[2009-10]Status: DisposedITAT Mumbai15 Jun 2021AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blem/S. Swargamrut Dairy Pvt. Ltd., V. Dcit – 11(2)(2) 113, 1St Chamber Income Tax Office, Churchgate Maker Chamber-V Mumbai - 400020 Nariman Point – 400021 Pan: Aalcs3714R (Appellant) (Respondent) Assessee By : Shri Vishnu Agarwal Department By : Shri Vijaykumar Menon Date Of Hearing : 18.03.2021 Date Of Pronouncement : 15.06.2021

For Appellant: Shri Vishnu AgarwalFor Respondent: Shri Vijaykumar Menon

Section 143Section 143(1)Section 147Section 68

assessee to establish the identity and the credit worthiness of the creditor as well as the genuineness of transaction. 5. The identity of creditors an be established by either furnishing their PANs or assessment orders. The genuineness of the transaction can be proved if it was shown that the money

ACIT Central Circle 3(2), Chennai vs. Cmg Steels Pvt. Ltd., Chennai

ITA 1985/CHNY/2017[2011-12]Status: DisposedITAT Chennai09 Jun 2021AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 1985/Chny/2017 िनधा"रण वष" / Assessment Year: 2011-12 The Asst. Commissioner Of M/S. Cmg Steels Pvt. Ltd., Income Tax, V. No.8, Elanthanur, Central Circle – 3(2), Ponneri High Road, Chennai – 34. Chennai – 600 103. Pan: Aadcc 7579C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co No.: 155/Chny/2017 (In Ita No.1985/Chny/2017) िनधा"रण वष" / Assessment Year: 2011-12 M/S. Cmg Steels Pvt. Ltd., The Asst. Commissioner Of Income Tax, V. No.8, Elanthanur, Central Circle – 3(2), Ponneri High Road, Chennai – 34. Chennai – 600 103. Pan: Aadcc 7579C (अपीलाथ"/Appellant) (""यथ"/Respondent) राज" की ओर से /Revenue By : Shri S. Bharath, Cit "नधा"रती क" ओर से/Assessee By : Shri T. Banusekar, Advocate सुनवाई क" तार"ख/Date Of Hearing : 25.03.2021 घोषणा क" तार"ख/Date Of Pronouncement : 09.06.2021

For Appellant: Shri T. Banusekar, AdvocateFor Respondent: Shri S. Bharath, CIT

Section 153CSection 68

that the assessee has discharged its onus by filing various details including name and address and PAN numbers of the creditors to prove identity of creditors. The assessee has further filed financial statements of creditors to prove creditworthiness. The assessee has also filed bank statements to prove the fact that

Jayant Packaging Pvt. Ltd., Chennai vs. DCIT Corporate Ward 2(2), Chennai

In the result, the appeal filed by the assessee for assessment year 2012-13 in ITA No

ITA 731/CHNY/2018[2012-13]Status: DisposedITAT Chennai21 Apr 2021AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 730, 731 & 732/Chny/2018 िनधा"रण वष" / Assessment Years: 2010-11, 2012-13 & 2012-13

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri Suresh Periasamy, JCIT

Section 115JSection 14A

assessee that the creditor is having creditworthiness to provide loan. Therefore, we are of considered 11 I.TA. Nos.730 to 732/Chny/2018 view that once identity of creditor is proved and genuineness of transaction is established then merely for the reason that loan is received in cash no addition can be made

Jayant Packaging Pvt. Ltd., Chennai vs. DCIT Corporate Ward 2(2), Chennai

In the result, the appeal filed by the assessee for assessment year 2012-13 in ITA No

ITA 730/CHNY/2018[2010-11]Status: DisposedITAT Chennai21 Apr 2021AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 730, 731 & 732/Chny/2018 िनधा"रण वष" / Assessment Years: 2010-11, 2012-13 & 2012-13

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri Suresh Periasamy, JCIT

Section 115JSection 14A

Jayant Packaging Pvt. Ltd., Chennai vs. DCIT Corporate Ward 2(2), Chennai

In the result, the appeal filed by the assessee for assessment year 2012-13 in ITA No

ITA 732/CHNY/2018[2012-13]Status: DisposedITAT Chennai21 Apr 2021AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 730, 731 & 732/Chny/2018 िनधा"रण वष" / Assessment Years: 2010-11, 2012-13 & 2012-13

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri Suresh Periasamy, JCIT

Section 115JSection 14A

ITO-15(3)(3), Mumbai vs. Satyam Roller Flour Mills Pvt. Ltd., Mumbai

In the result, the appeal for the AY 2013-14 is allowed

ITA 373/MUM/2019[2013-14]Status: DisposedITAT Mumbai17 Mar 2021AY 2013-14

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm आयकर अपील सं/ I.T.A. No. 373/Mum/2019 (िनधा"रण वष" / Assessment Year: 2013-14) बनाम/ Ito 15(3)(3) Satyam Roller Flour Mills R. No.452, Aayakar Bhavan, Pvt. Ltd. Vs. R-12, Ttc Industrial Area, Mumbai-400020. Midc Near Rabale Telephone Exchange, Navi Mumbai-400701. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacs4131R (अपीलाथ" /Appellant) (""थ" / Respondent) .. Revenue By: Shri T. S. Khalsa (Sr. Ar) Assessee By: Shri Suchek Anchaliya सुनवाई की तारीख / Date Of Hearing: 04/02/2021 घोषणा की तारीख /Date Of Pronouncement: 17/03/2021 आदेश / O R D E R Per Amarjit Singh, Jm:

For Appellant: Shri Suchek AnchaliyaFor Respondent: Shri T. S. Khalsa (Sr. AR)

Section 10Section 132Section 143(2)Section 28Section 68

ingredients in order to discharge burden of proof placed upon him u/s. 68 of the Act ie., the assessee has to prove the identity of creditor, creditworthiness of the creditor and genuineness of the transactions. In the instant case, the assessee has furnished confirmation obtained from Rose Impex, which contained ... address of the creditor. The assessee has documents prove the Identity of creditor. The assessee has also furnished ‘bank account of Rose impex and also it's own bank account in order to show that the loan transaction has been carried out through banking channel. Though, the learned CITA

DCIT CC 8(1), Mumbai vs. M/S Jainam Investments, Mumbai

In the result, appeals filed by the revenue are hereby dismissed

ITA 4474/MUM/2019[2016-17]Status: DisposedITAT Mumbai25 Feb 2021AY 2016-17

For Appellant: Shri Suchek Anchaliya (AR)For Respondent: Shri Rahul Raman (DR)

Section 143(1)Section 148Section 68

statement might have been relied upon; and, (4) failure to recognize the satisfactory nature of the explanation/evidence tendered by the appellant to explain identity of creditors, creditworthiness of the creditors and the genuineness of the loan transactions. Hence, the impugned addition of Rs.24.75 crore is hereby deleted." 17. There should

DCIT, Circle-17(1), New Delhi vs. Mps Infotecnics Pvt. Ltd., New Delhi

In the result ground number 5 and 6 of the appeal of the learned assessing officer are dismissed

ITA 6939/DEL/2017[2011-12]Status: DisposedITAT Delhi21 Jan 2021AY 2011-12

Bench: Shri H.S.Sidhu & Shri Prashant Maharishi(Through Video Conferencing) The Deputy Commissioner Of Vs. Mps Infotecnics Pvt. Ltd, Income Tax (Formerly Known As Visesh Circle-17(1), Infotecnic Ltd), 703, Arunachal New Delhi Building, 19, Barakhamba Road, Connaught Place, New Delhi Pan: Aaacv4805B (Appellant) (Respondent)

For Appellant: Shri R. S. Singhvi, CAFor Respondent: Ms. Pramita M. Biswas, CIT DR

Section 143(3)Section 250(4)Section 32(1)Section 68

that when the assessee has failed to prove the creditworthiness and the genuineness of the transaction, mere filing of the proof of the identity of creditors and that the transactions are made by issue of cheques are not sufficient. He therefore stated that that the learned assessing officer has correctly

The Dy. Commissioner of Income Tax, Circle-2(3), Surat vs. M/S. Shhlok Enterprise, Surat

In the result the grounds of appeal raised by the revenue are dismissed

ITA 2018/AHD/2016[2012-13]Status: DisposedITAT Surat06 Jan 2021AY 2012-13

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Court Hearing) Deputy Commissioner Of Income Vs. M/S. Shhlok Enterprise, Tax, Circle-2(3), Surat Block No.292, Plot No.135/B, Shhlok Arcede, Bamroli Road, Surat. Pan : Abufs8091E Appellant Respondednt

Section 131Section 133ASection 143(3)Section 68

statement was obtained under any duress or presser. No such averment was ever made by the assessee. The assessee failed to prove the identity of creditor, creditworthiness of creditor and the genuineness of transaction. During the assessment or during the first appellate authority, the assessee failed to bring any material

Dy CIT CC 2 (2), Mumbai vs. Smt. Kalpana Mukesh Ruia, Mumbai

The appeal stands dismissed

ITA 6962/MUM/2019[2012-13]Status: DisposedITAT Mumbai31 Dec 2020AY 2012-13

Section 143(1)Section 143(3)Section 153ASection 68

genuineness of the transactions of sale of shares of PAL, the assessee has submitted following documents/ evidences: - a) To prove the identity of creditor and nature of transaction the assessee submitted copy of Contract note on sale by Geojit on BSE platform. The contract notes shows the quantity, rate, time

Kalpna Mukesh Ruia, Mumbai vs. DCIT CC 2 (2), Mumbai

The appeal stands dismissed

ITA 6519/MUM/2019[2012-13]Status: DisposedITAT Mumbai31 Dec 2020AY 2012-13

Section 143(1)Section 143(3)Section 153ASection 68

ACIT, Central Circle-3, Jodhpur vs. Bhanwar Singh Rathore, Pali

Accordingly, it is held that the AO rightly added Rs.19,06,200/- u/s 68 of the IT. Act,1961. The appellant fails on this ground. The ground raised by the appellant regarding this issue is, hereby, ...

ITA 347/JODH/2019[2012-13]Status: DisposedITAT Jodhpur21 Dec 2020AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No.347/Jodh/2019 ("नधा"रणवष" / Assessment Year: 2012-13) Acit-Central Circle-2 Bhanwar Singh Rathore बनाम/ Room No.68, Income Tax Office Bagh Niwas, Sumerpur Road Paota, C-Road Village-Mandali, Hemawas, Pali Vs. Jodhpur, Rajasthan- 342 006. Rajasthan-306 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abepr-9925-L (अपीलाथ"/Appellant) (""यथ" / Respondent) : & C.O. No.02/Jodh/2020 (Arising Out Of Ita No.347/Jodh/2019 ("नधा"रणवष" / Assessment Year: 2012-13) Bhanwar Singh Rathore Acit-Central Circle-2 बनाम/ Bagh Niwas, Sumerpur Road Room No.68, Income Tax Office Village-Mandali, Hemawas, Pali Paota, C-Road Vs. Rajasthan-306 401 Jodhpur, Rajasthan- 342 006. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abepr-9925-L (अपीलाथ"/Appellant) (""यथ" / Respondent) :

For Appellant: Shri Rajendra Jain (Advocate) & MsFor Respondent: Shri A.S. Yadav- Ld. Sr. DR

Section 143(3)

substantiate this claim, the appellant produced affidavit of Shri Raju Bhai who had been assessed to tax regularly. The appellant had established the identity of creditor, his creditworthiness and genuineness of transactions within the meaning of section 68 of the Act. 4. Agricultural income:-Rs. 44,00,000/- : The appellant

DCIT, Circle, Bhilwara vs. M/S. Saileela Synthetics Pvt. Ld., Bhilwara

The appeal stands dismissed

ITA 279/JODH/2018[2015-16]Status: DisposedITAT Jodhpur21 Dec 2020AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am (Hearing Through Video Conferencing Mode) आयकरअपील सं./ I.T.A. No.279/Jodh/2018 ("नधा"रणवष" / Assessment Year: 2015-16) Dcit- Bhilwara Circle M/S. Saileela Synthetics Pvt. Ltd. बनाम/ Shastri Nagar, Bhilwara 147, New Cloth Market Rajasthan. Pur Road, Bhilwara Vs. Rajasthan-311 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcs-1103-N (अपीलाथ"/Appellant) (""यथ" / Respondent) :

For Appellant: Shri Rajendra Jain (Advocate) & MsFor Respondent: Shri A.S. Yadav- Ld. CIT- DR

Section 133(6)Section 143(3)Section 36(1)(va)Section 68

been considered but not found satisfactory and Assessee Company failed to furnish any explanation in this regard. To substantiate any credits the books - identity of creditors, genuineness of transactions and creditworthiness of the creditors is required to be proved. In the present case, assessee company has stated to have received