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“creditworthiness of the creditor”

Cash Credits & Unexplained ItemsSection 68Section 68914 judgments

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

Leading authorities on creditworthiness of the 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.

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.

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.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

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

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.

Judgments citing creditworthiness of the creditor

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

Chartered Accountants. 8. The Ld. CIT (A)erred in upholding the addition made by the AO even though the Identity, Genuineness and Creditworthiness of the creditors is proved. 9. The Ld. CIT(A) ought to have deleted the addition on the fact that the onus on the assessee is discharged ... when the Identity, Genuineness and creditworthiness of the creditors is proved. 10. The assessee may add, alter or modify any other points to the grounds of appeal at any time before or at the time of hearing of the appeal”. 3. This is the second round of appeal, as earlier

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

below and he emphasized that the critical ingredients for escaping the rigours of Section 68 of the Act, viz. proving the identity and creditworthiness of the creditors and proving the genuineness of the transaction, were missing. The Ld. DR stated that it was not only on account

Stepping Stones Infocom Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2246/KOL/2024[2013-2014]Status: DisposedITAT Kolkata30 Jan 2025AY 2013-2014

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 131Section 143(2)Section 68

returned un-served or no body complied with them is of little significance to prove the genuineness of the transactions and identity and creditworthiness of the creditors. The relevant portion of the decision is extracted below: “We find considerable force of the submissions of the learned Counsel for the appellant ... returned un-served or no body complied with them is of little significance to prove the genuineness of the transactions and identity and creditworthiness of the creditors. The relevant portion of the decision is extracted below: “We find considerable force of the submissions of the learned Counsel for the appellant

Income Tax Officer, Dhule vs. Dhule Zilha Parishad Karmachari Sahakari Patpedhi Maryadit Dhule, Dhule

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

ITA 769/PUN/2024[2020-21]Status: DisposedITAT Pune28 Jan 2025AY 2020-21

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

For Appellant: Shri Sanket M. JoshiFor Respondent: Shri Amol Khairnar
Section 143(1)(a)Section 143(2)Section 144Section 68Section 80P(2)(a)

considering the additional evidence filed by the assessee 3 ITA No.769/PUN/2024, AY 2020-21 observed that the assessee has satisfactorily explained the identity, creditworthiness of the creditors and genuineness of the transactions and hence the Ld. AO is not justified in applying the provisions of section

ACIT Circle-22(1), Mumbai vs. Raheja Legacy Trust, Mumbai

In the result, the appeal of the assessee is partly allowed and appeal filed by the Revenue is dismissed

ITA 2826/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Amarjit Singhassessment Year: 2018-19

For Appellant: Shri Bharat Raichandani & Bhagrati SahuFor Respondent: Smt. Sanyogita Nagpal, CIT/DR
Section 250Section 68

facts, the ITAT held as follows – 1. 1. The parameters to explain the nature and source of a credit are regarding the identity, creditworthiness of the creditor and the genuineness. However, the above said conventional parameters have to be applied keeping in mind the peculiar circumstances of the case

Raheja Legency Trust, Mumbai vs. ACIT, Cir-22(1), Mumbai

In the result, the appeal of the assessee is partly allowed and appeal filed by the Revenue is dismissed

ITA 2268/MUM/2024[2018-19]Status: DisposedITAT Mumbai28 Jan 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Amarjit Singhassessment Year: 2018-19

For Appellant: Shri Bharat Raichandani & Bhagrati SahuFor Respondent: Smt. Sanyogita Nagpal, CIT/DR
Section 250Section 68

facts, the ITAT held as follows – 1. 1. The parameters to explain the nature and source of a credit are regarding the identity, creditworthiness of the creditor and the genuineness. However, the above said conventional parameters have to be applied keeping in mind the peculiar circumstances of the case

Sarvesh Bardia, Rajnandgaon vs. Income Tax Officer-1, Rajnandgaon

In the result, appeal filed by the assessee is partly allowed for statistical purposes in terms of our aforesaid observations

ITA 299/RPR/2024[2017-18]Status: DisposedITAT Raipur23 Jan 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.299/Rpr/2024 "नधा"रण वष" / Assessment Year : 2017-18 Sarvesh Bardia Bardia Niwas, Sadar Bazar, Rajnandgaon (C.G.)-491 441 Pan: Aqbpb3485F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1, Rajnandgaon (C.G.) ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri S.L Anuragi, CIT-DR
Section 143(2)Section 143(3)Section 69A

aforesaid claim of the assessee. Our aforesaid view that in a case where the A.O without making any independent enquiry to disprove the creditworthiness of the creditors, had without dislodging the documentary evidences filed by the assessee in support thereof made additions contrary to confirmations filed by the lenders, then ... Chhattisgarh). As the A.O. in the case before the Hon’ble High Court had not made any independent verification to disprove the creditworthiness of the creditors, as was established by affidavits and statements of the creditors disclosing their respective sources of income, therefore, on appeal, the said addition was vacated

Achla Malhotra, Delhi vs. ITO, Ward-24(1), Delhi

ITA 4252/DEL/2024[2014-15]Status: DisposedITAT Delhi23 Jan 2025AY 2014-15

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

Section 132Section 132(4)Section 147

1158/2007 has held that: “The authorities below found vis-a-vis the genuineness of the transactions and the creditworthiness of their creditors : (i) the fact that there was sufficient balance available with the creditors when cheques have been issued to the assessee company was established; (ii) it was also established ... event the Revenue still had a doubt with regard to the genuineness of the transactions in issue, or as regards the creditworthiness of the creditors, it would have had to discharge the onus which had shifted on to it. A bald assertion by the AO that the credits were

Income Tax Officer 41(3)(1), Mumbai, Kautilya Bhavan vs. Bhagwati Prasad N Rungta, India

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

ITA 1574/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Jan 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Mrs. Renu Jauhriassessment Year: 2015-16

For Appellant: Shri Madhur Agarwal, Ld. A.R. &For Respondent: Shri Laxmi Kant, Ld. Sr. D.R
Section 131Section 142(1)Section 143(3)Section 250

addition towards unexplained credits under section 68 of the Income Tax Act unsustainable as genuineness, 8 Mr. Bhagwati Prasad N Rungta identity and creditworthiness of the creditors proved (Copy attached in Paper Book Pg. No. 132 to 151). Commissioner of Income Tax -II vs Kamdhenu Steel & Alloys Ltd. (High Court ... Acknowledgment, loan balance confirmation, bank statement and certification of registration with NBFC, however ignoring all these, the AO had concluded that identity, creditworthiness of the creditors and genuineness of transaction has not been proved. Further, since the said loans have been repaid in the subsequent years, the question of getting

Nehal Brothers, Mumbai vs. Income Tax Officer 23(2)(1), Mumbai

In the result, the appeal in respect of the five creditors stand allowed

ITA 2541/MUM/2023[2016-17]Status: DisposedITAT Mumbai22 Jan 2025AY 2016-17

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaranassessment Year : 2016-17 Nehal Brothers, Income Tax Officer-23(2)(1), Ew 4030, Piramal Chambers, Bharat Diamond Bourse, Vs. Dr. Ss Rao Marg, Bandra Kurla Complex, Lalbaugh, Lower Parel, Bandra (East), Mumbai. Mumbai Pan : Aajfm6428R (Appellant) (Respondent)

For Appellant: Shri R.S. KhandelwalFor Respondent: Ms. Monica Pande, Sr.DR
Section 68

assessee did not furnish the documents to prove the three main ingredients viz., the identity of the creditors, the creditworthiness of the creditors and the genuineness of the transaction. 5. In the appellate proceedings before the Ld.CIT(A), the assessee furnished all the documents relating to all creditors to prove ... bank accounts before giving loan to the assessee, which might have warranted further probe. Hence, we are of the view that the creditworthiness of the creditors would also stand proved. Since the loan transaction has taken place through banking channels, in our view, the genuineness of the transaction also stood

Samkeet Arya Homes LLP, Ahmedabad vs. The ITO, Ward-3(3)(5), Ahmedabad

In the result, Ground Number 2 of the assessee’s appeal is dismissed

ITA 365/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad16 Jan 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Sunjal Shah, A.RFor Respondent: Shri B.P. Srivastava, Sr. DR
Section 68

aspects must be proven for any credit entry in the books of an assessee: first, the identity of the creditor; second, the creditworthiness of the creditor; and third, the genuineness of the transaction. While the assessee submitted that it has met the initial onus by giving the relevant documentation ... view, the creditworthiness of the creditors has not been sufficiently established. We note that the Assessing Officer reviewed the ITRs and bank statements of these creditors and held that they are individuals with limited financial means, making it questionable that they could have lent the amounts reflected in the assessee

Sanjay Kumar Agarwal, Hyderabad vs. ACIT., Circle-1(1), Hyderabad

In the result, the appeal of the assessee is partly allowed

ITA 485/HYD/2024[2017-18]Status: DisposedITAT Hyderabad15 Jan 2025AY 2017-18

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaassessment Year: 2017-18 Sanjay Kumar Agarwal, Vs. The Assistant Commissioner Of Income Tax, Hyderabad. Circle 1(1), Hyderabad. Pan : Abfpa5945G. (Appellant) (Respondent) Assessee By: Shri Sunil Kumar Jain, C.A. Revenue By: Dr. Sachin Kumar, Sr.Dr. Date Of Hearing: 09.01.2025 Date Of Pronouncement: 15.01.2025

For Appellant: Shri Sunil Kumar Jain, C.AFor Respondent: Dr. Sachin Kumar, Sr.DR
Section 143(3)Section 144Section 68

remand report, 4 ITA 485/Hyd/2024 reproduced on page 11 of the order of the Ld. CIT(A), indicated that the genuineness and creditworthiness of the creditors is beyond doubt. However, despite this finding, the Ld. CIT(A) confirmed the additions, stating that the funds were credited to the assessee ... established. 7. Per contra, the ld. DR submitted that the remand report submitted by the Assessing Officer clearly cast doubt on the creditworthiness of the creditors. The ld. DR referred to the tabular remarks provided on pages 13 and 14 of the Ld. CIT(A)'s order, which supported

Assistant Commissioner of Income Tax, Circle - 7(1), Kolkata vs. Urgaya Foods and Feeds Private Limited, Jalpaiguri

In the result, the appeal of the Revenue is dismissed

ITA 1116/KOL/2024[2021-2022]Status: DisposedITAT Kolkata15 Jan 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Urgaya Foods & Fees Private Limited Asst. Commissioner Of Income 12A, Dabgram Industrial Tax, Circle-7(1), Kolkata Centre, Fulbari, Near Krishna Aaykar Bhavan, P-7, Vs. Chowringhee Square, Weight Bridge, Kolkata-700069, West Bengal Jalpaiguri-743015 West Bengal (Appellant) (Respondent) Pan No. Aaacu8901B Assessee By : Shri Amit Agarwal, Ar Revenue By : Shri Sailen Samadder, Dr Date Of Hearing: 07.01.2025 Date Of Pronouncement : 15.01.2025

For Appellant: Shri Amit Agarwal, ARFor Respondent: Shri Sailen Samadder, DR
Section 143(1)Section 68

assessee by holding that the ld. AO has not considered the documents and information furnished by the assessee regarding identity, genuineness and creditworthiness of the creditors, whereas the assessee had duly discharged its onus cast upon him u/s 68 of the Act. The ld. CIT (A) after considering the submissions

Dy. Commissioner of Income Tax-1(1), Raipur vs. Agrawal Global Infratech Pvt. Ltd., Raipur

ITA 331/RPR/2024[2018-19]Status: DisposedITAT Raipur09 Jan 2025AY 2018-19

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 331/Rpr/2024 (िनधा"रण वष" Assessment Year: 2018-19)

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 144BSection 250Section 40aSection 68

Agrawal is hereby directed to be deleted. (v) Agrawal Infra-Shree Balaj JV Rs. 5,00,00,000/- : The AO has doubted the creditworthiness of the creditor as income in ITR is Rs. 0/- During the appeal proceedings, the appellant explained that the creditor is a Joint Venture ... from the State of Jharkhand, which has then been transferred to the appellant. All details to establish the identity, genuineness and creditworthiness of this creditor are duly furnished and there is no justification for treating this amount as unexplained cash credit u/s 68. Thus, the addition

Income Tax Officer, Ward 11(1), Hyderabad vs. Abhi Constructions, Hyderabad

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

ITA 1021/HYD/2024[2021-22]Status: DisposedITAT Hyderabad09 Jan 2025AY 2021-22

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1021/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2021-22) Income Tax Officer Vs. Abhi Constructions Ward 11(1) Bachupally, Hyderabad Hyderabad Pan:Abdfa8081H (Appellant) (Respondent) राज" व "ारा/Revenue By:: Shri Srinath Sadanala, Dr िनधा""रती "ारा/Assessee By: N O N E सुनवाई की तारीख/Date Of Hearing: 08/01/2025 घोषणा की तारीख/Pronouncement: 09/01/2025 आदेश/Order

For Appellant: N O N EFor Respondent: : Shri Srinath Sadanala, DR
Section 142(1)Section 68

account of unsecured loans during the year under consideration when the assessee has failed to discharge its onus to prove the identity and creditworthiness of the creditors as well as the genuineness of the transaction. He has referred to the assessment order and submitted that the assessee has failed

ITO, Ward-1, Madikeri vs. Sri. M.L. Krupal, Kodagu

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

ITA 382/BANG/2012[2005-06]Status: DisposedITAT Bangalore09 Jan 2025AY 2005-06

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2005-06 Late M.L. Krupal M/S. Prime Commodities Blv Complex Somwarpet 571 236 Represented By Legal Heir Suvina Krupal Ito Vs. C/O Shreehari Kutsa, Advocate Ward-1 No.2B, 2Nd Floor, ‘Solus’, Madikeri 1St Cross J.C. Road Bangalore 560 027

For Appellant: Smt. Harsha J., A.RFor Respondent: Sri V. Parithivel, D.R

creditors. Further, confirmation letters from all the three creditors dated 09.12.2012 by way of additional evidence were furnished on 12.02.2013 thereby proving the creditworthiness of the creditors by way of producing RTC/Pahani and confirmation letters and accordingly prayed to delete the addition on this account

Mr. M.L. Krupal, Kodagu vs. ITO, Ward-1, Madikeri

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

ITA 380/BANG/2012[2005-06]Status: DisposedITAT Bangalore09 Jan 2025AY 2005-06

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2005-06 Late M.L. Krupal M/S. Prime Commodities Blv Complex Somwarpet 571 236 Represented By Legal Heir Suvina Krupal Ito Vs. C/O Shreehari Kutsa, Advocate Ward-1 No.2B, 2Nd Floor, ‘Solus’, Madikeri 1St Cross J.C. Road Bangalore 560 027

For Appellant: Smt. Harsha J., A.RFor Respondent: Sri V. Parithivel, D.R

creditors. Further, confirmation letters from all the three creditors dated 09.12.2012 by way of additional evidence were furnished on 12.02.2013 thereby proving the creditworthiness of the creditors by way of producing RTC/Pahani and confirmation letters and accordingly prayed to delete the addition on this account

Deputy Commissioner of Income Tax, Circle 1(1), Jabalpur vs. Shri Indrabhan Singh Rathore, Narsinghpur

In the result, appeal filed by the Revenue is dismissed

ITA 234/JAB/2018[2015-16]Status: HeardITAT Jabalpur08 Jan 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Shri. Aok Bhura, DRFor Respondent: Shri Sapan Usrethe, Adv
Section 143(3)Section 250Section 68

them did not comply with the said summons. It was, therefore, submitted there were good and sufficient reasons to show that the identity, creditworthiness of the creditors and the genuineness of the transactions were not proved and therefore, the ld. AO was justified in adding these amounts back under section

Income Tax Officer, Aayakar Bhawan, Poorva vs. Amodini Vyapar Pvt Ltd, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1481/KOL/2024[2012-13]Status: DisposedITAT Kolkata31 Dec 2024AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Amodini Vyapar Pvt. Ltd. Income Tax Officer, Kalpanalaya, Avirampur, Po- 7Th Floor, Nadt Building, Aaykar Bhavan Poorva, 110 Shantipally, Budge Budge, Vs. Kolkata-700107 Kolkata-700137, West Bengal (Appellant) (Respondent) Pan No. Aacca2332G Assessee By : Shri Sunil Surana, Ar Revenue By : Shri Pradip Kumar Biswas, Dr Date Of Hearing: 26.11.2024 Date Of Pronouncement : 31.12.2024

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Pradip Kumar Biswas, DR
Section 131Section 131(1)Section 142(1)Section 144Section 14ASection 68Section 68o

returned un- served or no body complied with them is of little significance to prove the genuineness of the transactions and identity and creditworthiness of the creditors. The relevant portion of the decision is extracted below: “We find considerable force of the submissions of the learned Counsel for the appellant

Masineni Hotels Private Limited, Anantapur vs. ACIT, Circle-1, Anantapur

In the result, appeal filed by the assessee is allowed

ITA 346/HYD/2023[2016-17]Status: DisposedITAT Hyderabad30 Dec 2024AY 2016-17

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.346/Hyd/2023 (निर्धारण वर्ा/Assessment Year: 2016-17) Masineni Hotels Private Vs. Acit, Circle-1 Limited Anantpur Anantapur [Pan : Aahcm6211F] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Mohd.Afzal, Ar रधजस् व द्वधरध/Revenue By:: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 10/12/2024 घोर्णध की तधरीख/Date Of 30/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2023 Of The Learned Commissioner Of Income Tax (Appeals) [Ld.Cit(A)], National Faceless Appeal Centre, Delhi, Pertaining To A.Y.2016-17 On The Following Grounds : 1. Under The Facts & Circumstances Of The Case The Learned Cit(A), Nfac, New Delhi Erred In Confirming The Addition Of Rs.2,35,48,000/- Being The Difference In The Share Capital, Share Application & Other Loan Subscribed / Given By Managing Director Shri M.Ramaiah U/S 68 Of The Income Of The Income Tax Act, 1961 (“The Act”), 1961 (The Act).

For Appellant: Mohd.Afzal, ARFor Respondent: : Shri Srinath Sadanala, DR
Section 68

appellant is having sufficient source for explaining the amount invested in the appellant company, argued that the appellant has discharged the identity, creditworthiness of the creditor and also genuineness of the transaction. The Assessing Officer, after considering the submissions of the assessee and also taking note of the relevant facts