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“creditworthiness of the creditor”

Cash Credits & Unexplained ItemsSection 68Section 68914 judgments

NARAYAN BARTER PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER,WARD-6(1),KOLKATA, KOLKATA

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

ITA 2572/KOL/2025[2011-12]Status: DisposedITAT Kolkata20 Mar 2026AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(2)Section 147Section 148Section 151Section 250Section 271(1)(c)Section 68

dismissed. 10. Ground no.5:- In Ground 5 of the appeal, the assessee contended that the AO had wrongly concluded that there was no creditworthiness of the creditors and questioned the genuineness of the transactions without conducting any enquiry or seeking confirmation from the parties involved. The assessee argued that ... correct in treating the receipts as unexplained cash credit because the assessee did not furnish sufficient evidence to establish the identity, genuineness, and creditworthiness of the creditors to the satisfaction of the AO. The case law relied upon by the assessee is not applicable to the facts of the present

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7842/DEL/2025[2022-23]Status: DisposedITAT Delhi20 Mar 2026AY 2022-23

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE

DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. M/S VESTIGE MARKETING PRIVATE LIMITED, DELHI

ITA 7840/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Mar 2026AY 2020-21

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE

VESTIGE MARKETING PVT LTD,DELHI vs. DCIT CENTRAL CIRCLE -05 , DELHI

ITA 5521/DEL/2025[2024-25]Status: DisposedITAT Delhi20 Mar 2026AY 2024-25

Bench: Shri Before Shri Satbeer Singh Godarabefore Shri Before Shri Satbeer Singh Godarasatbeer Singh Godara & Satbeer Singh Godara & And & Shri Naveen Chandra Shri Naveen Chandra, , , Shri Naveen Chandra Shri Naveen Chandra

For Appellant: Shri Amit Goel and Shri Pranav Yadav, Advocate
Section 132Section 143(3)Section 147Section 37Section 37(1)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE INCOME TAX APPELLATE TRIBUNAL IN THE

NARENDRA BANSAL,DELHI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRLCE -12(2), NEW DELHI

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 6178/DEL/2025[2016-17]Status: DisposedITAT Delhi19 Mar 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanasstt. Year : 2016-17 Narendra Bansal, Vs. Acit, Circle 12(2), A-61, Okhla Industrial Area, Delhi Phase-Ii, New Delhi – 110 020 C.R. Building, I.P. Estate, New Delhi – 2 [Pan: Ahdpb0964E) (Appellant) (Respondent) Appellant By : Sh. Ankit Kumar, Adv. Respondent By : Sh. Manish Gupta, Sr. Dr.

For Appellant: Sh. Ankit Kumar, AdvFor Respondent: Sh. Manish Gupta, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 68

onus under section 68 by proving the identity of the creditor, the genuineness of the transaction and the 2 | P a g e creditworthiness of the creditor, the burden shifted on the Department to prove otherwise, which was not done. 7. That the AO has erred in passing the impugned ... primary onus under section 68 of the Act by proving the identity of the creditor, the genuineness of the transaction and the creditworthiness of the creditor, the burden shifted on the Department to prove otherwise, which was not done. 6. On the other hand, Ld. DR relied upon the orders

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1392/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

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

Section 250Section 68

inquiry conducted in case of lending entities has clearly established the doubtful creditworthiness of these entities and the assessee failed to establish the creditworthiness of the creditors. 3. On the facts and in the circumstances of the case and in law the Ld. CIT(A) has erred in deleting ... well-settled legal proposition that the initial onus lies on the assessee to establish the identity of the creditor, the creditworthiness of the creditor, and the genuineness of the transaction. In the case before us, we find that the assessee has undisputedly filed all the relevant documents before the Assessing

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1278/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

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

Section 250Section 68

inquiry conducted in case of lending entities has clearly established the doubtful creditworthiness of these entities and the assessee failed to establish the creditworthiness of the creditors. 3. On the facts and in the circumstances of the case and in law the Ld. CIT(A) has erred in deleting ... well-settled legal proposition that the initial onus lies on the assessee to establish the identity of the creditor, the creditworthiness of the creditor, and the genuineness of the transaction. In the case before us, we find that the assessee has undisputedly filed all the relevant documents before the Assessing

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1277/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2014-15

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

Section 250Section 68

inquiry conducted in case of lending entities has clearly established the doubtful creditworthiness of these entities and the assessee failed to establish the creditworthiness of the creditors. 3. On the facts and in the circumstances of the case and in law the Ld. CIT(A) has erred in deleting ... well-settled legal proposition that the initial onus lies on the assessee to establish the identity of the creditor, the creditworthiness of the creditor, and the genuineness of the transaction. In the case before us, we find that the assessee has undisputedly filed all the relevant documents before the Assessing

ABDUL SALAM SHAIK,PILER vs. INCOME TAX OFFICER, WARD-1(1), TIRUPATI

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

ITA 1371/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Mar 2026AY 2017-18
Section 142(1)Section 143(2)Section 143(3)Section 250Section 69

furnishing verifiable evidence of confirmation of the creditor and\nbank statement of the creditor. However, these details are not furnished. With regard\nto creditworthiness of the creditor, the source in the hands of the creditor are required\nto be proved with documentary evidences. In the absence of these evidences ... furnishing verifiable evidence\nof confirmation of the creditor and bank statement of the creditor. However, these\ndetails are not furnished. With regard to creditworthiness of the creditor, the source\nin the hands of the creditor are required to be proved with documentary evidences.\nIn the absence of these evidences

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1217/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

made merely on the basis of suspicion. One the assessee has filed all the details, the burden of proving the genuineness and creditworthiness of the creditor stood discharged by the assessee. The bench also referred to the decision of Hon’ble Gujarat High Court in the case of PCIT ... made merely on the basis of suspicion. Once the assessee has filed all the details, the burden of proving the genuineness and creditworthiness of the creditor stood discharged by the assessee. The other decisions as placed on record by Ld. AR also support the same view. On the basis

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1066/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

made merely on the basis of suspicion. One the assessee has filed all the details, the burden of proving the genuineness and creditworthiness of the creditor stood discharged by the assessee. The bench also referred to the decision of Hon’ble Gujarat High Court in the case of PCIT ... made merely on the basis of suspicion. Once the assessee has filed all the details, the burden of proving the genuineness and creditworthiness of the creditor stood discharged by the assessee. The other decisions as placed on record by Ld. AR also support the same view. On the basis

DAVINDER KUMAR MAGO,PUNJABI BAGH vs. DCIT/ACIT CENTRAL CIRCLE, DDN, DEHRADUN

In the result appeal of the assessee is allowed

ITA 17/DDN/2026[2019-20]Status: DisposedITAT Dehradun12 Mar 2026AY 2019-20

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2019-20] Davinder Kumar Mago Vs Dcit/Acit 12/1, Punjabi Bagh, Central Circle, External Punjabi Bagh, Dehradun New Delhi-110026 Uttarakhand Pan-Ajhpm9802A Appellant Respondent Appellant By Shri Ajay Wadhwa, Adv. (Vc) Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 12.03.2026 Order Per Manish Agarwal, Am : This Appeal Filed By The Assessee Against The Order By Pr.Cit (Central), Kanpur At Meerut Passed U/S 263 Of The Income Tax Act, 1861 (“The Act”) Dated 08.01.2026 Arising Out Of The Order Passed U/S 143(3) R.W.S. 147 Of The Act.

Section 142(1)Section 143(3)Section 147Section 263

between “lack of inquiry” and “inadequate inquiry”. Once the AO has made the inquiry and reached to the satisfaction about the genuineness and creditworthiness of the creditors, it cannot be said that no inquiry was made by the AO. The Hon’ble Delhi High Court in the case

ACIT CIRCLE-1(1), RAJKOT, RAJKOT vs. GRENIC TILES PVT LTD, MORBI

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

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

n422305010037111, maintained with Union Bank of India during\ndemonetization period (i.e. 09.11.2019 to 30.12.2019). Since the primary\nonus to prove the identity and creditworthiness of the creditors and the\ngenunieness of the transaction so involved has been entrusted on the\nassessee, during the course of these proceedings, the assessee

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\nappeal of the revenue is dismissed

ITA 624/RJT/2025[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
Section 133(6)Section 143(3)Section 250Section 68

n422305010037111, maintained with Union Bank of India during\ndemonetization period (i.e. 09.11.2019 to 30.12.2019). Since the primary\nonus to prove the identity and creditworthiness of the creditors and the\ngenuniness of the transaction so involved has been entrusted on the\nassessee, during the course of these proceedings, the assessee

ACIT., CENTRAL CIRCLE-1(4), HYDERABAD vs. KVR CONSULTANCY PRIVATE LIMITED, HYDERABAD

In the result, the appeal filed by the Revenue is dismissed

ITA 212/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Mar 2026AY 2016-17
Section 132Section 147Section 148Section 251

nPvt. Ltd. are genuine and the assessee company has established the\nidentity of the loan creditor, the genuineness of the transaction and\nthe creditworthiness of the creditor. Thus, the Ld. CIT(A) directed the\nA.O. to delete the addition made towards loan received from M/s.\nOpus Holdings

PIYUSH ASHOK MEHTA,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI, 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

placed upon the shoulders of the assessee i.e. the assessee has to prove the three main ingredients namely – identity of the creditor, creditworthiness of the creditor and genuineness of the transactions. In the instant case it is not the case of the Assessing Officer that the assessee has failed

PIYUSH ASHOK MEHTA,MUMBAI vs. DCIT, CENTRAL CIRCLE 6(4), MUMBAI, 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

placed upon the shoulders of the assessee i.e. the assessee has to prove the three main ingredients namely – identity of the creditor, creditworthiness of the creditor and genuineness of the transactions. In the instant case it is not the case of the Assessing Officer that the assessee has failed

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

appellant has relied on a number of case laws to argue that the appellant cannot be held liable for the genuineness and creditworthiness of the creditors of his creditors. Moreover, the transactions of investment in the investor companies has been accepted by the Department in the orders

JCIT, (OSD), CIRCLE 1(1), RAIPUR, RAIPUR vs. PLATINUM WORLD HOSPITALITY PRIVATE LIMITED, RAIPUR, RAIPUR

In the result appeal filed by the appellant is allowed

ITA 130/RPR/2026[2014-15]Status: DisposedITAT Raipur10 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.130/Rpr/2026 "नधा"रण वष" /Assessment Year : 2014-15 The Joint Commissioner Of Income Tax (Osd), Circle-1(1), Raipur (C.G.)

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 68

appearing in its books, and judicial interpretation has consistently held that such explanation must establish (i) the identity of the creditor, (ii) the creditworthiness of the creditor, and (iii) the genuineness of the transaction. Further, by virtue of the proviso to Section 68 inserted w.e.f. 01.04.2013, a closely-held company

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

made merely on the basis of suspicion. Once the assessee has filed all the details, the burden of proving the genuineness and creditworthiness of the creditor stood discharged by the assessee. The other decisions as quoted 22 by Ld. AR in the written submissions lay down similar propositions and duly

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