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“genuineness of the transaction”

Cash Credits & Unexplained ItemsSection 68Section 685,938 judgments

The decision most relied on for genuineness of the transaction is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on genuineness of the transaction

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

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.

McDowell & Co. Ltd. v. CTO
154 ITR 148 · 1985 · Supreme Court
741
citing judgments

The Supreme Court held that while legitimate tax planning is permissible, transactions structured as a "colourable device" or "subterfuge" solely to avoid tax are impermissible. It mandates a judicial shift to look beyond the form to the substance of a transaction, allowing the lifting of the corporate veil in tax evasion arrangements.

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

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.

Umacharan Shaw & Bros. v. CIT
37 ITR 271 · 1959 · Supreme Court
567
citing judgments

An income tax assessment or addition cannot be sustained solely on the basis of suspicion, surmises, or conjectures, as strong suspicion does not amount to proof. The revenue authorities must rely on concrete evidence and material to frame an assessment.

Judgments citing genuineness of the transaction

Rnb Infrastructure P.Ltd, Delhi vs. DCIT, Central Circle-32, New Delhi

In the result, captioned appeals of the assessee are allowed

ITA 2592/DEL/2022[2017-18]Status: DisposedITAT Delhi16 Dec 2024AY 2017-18

Bench: Pradip Kumar Kedia & Shri Anubhav Sharmaita No.2588/Del/2022 (Assessment Year : 2013-14) Ita No.2590/Del/2022 (Assessment Year : 2015-16) Ita No.2592/Del/2022 (Assessment Year : 2017-18) Rnb Infrastructure Pvt. Ltd. Vs. Dcit, Rnb House, 1, Shivaji Enclave, Central Circle-32, Main Road, Near Raja Garden, Opp. New Delhi Mother Dairy, New Delhi-110027 Pan No. Aadcr0962Q (Appellant) (Respondent) Assessee By Shri Ved Jain, Adv. & Sh. Aman Garg, Ca Revenue By Ms. Suman Malik, Cit-Dr Date Of Hearing: 18.09.2024 Date Of Pronouncement: 16.12.2024 Order Per Pradip Kumar Kedia, Am : The Captioned Appeals Filed By The Assessee Against The Respective Orders Passed Under S. 250 Of The Income Tax Act, 1961 (The Act) By The Ld.Cit(A) Is Tabulated Hereunder:-

Section 1Section 153A

course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies ... course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies

Rnb Infrastructure P.Ltd, Delhi vs. DCIT, Central Circle-32, New Delhi

In the result, captioned appeals of the assessee are allowed

ITA 2591/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Dec 2024AY 2016-17

Bench: Pradip Kumar Kedia & Shri Anubhav Sharmaita No.2588/Del/2022 (Assessment Year : 2013-14) Ita No.2590/Del/2022 (Assessment Year : 2015-16) Ita No.2592/Del/2022 (Assessment Year : 2017-18) Rnb Infrastructure Pvt. Ltd. Vs. Dcit, Rnb House, 1, Shivaji Enclave, Central Circle-32, Main Road, Near Raja Garden, Opp. New Delhi Mother Dairy, New Delhi-110027 Pan No. Aadcr0962Q (Appellant) (Respondent) Assessee By Shri Ved Jain, Adv. & Sh. Aman Garg, Ca Revenue By Ms. Suman Malik, Cit-Dr Date Of Hearing: 18.09.2024 Date Of Pronouncement: 16.12.2024 Order Per Pradip Kumar Kedia, Am : The Captioned Appeals Filed By The Assessee Against The Respective Orders Passed Under S. 250 Of The Income Tax Act, 1961 (The Act) By The Ld.Cit(A) Is Tabulated Hereunder:-

Section 1Section 153A

course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies ... course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies

Rnb Infrastructure P.Ltd, Delhi vs. DCIT, Central Circle-32, New Delhi

In the result, captioned appeals of the assessee are allowed

ITA 2590/DEL/2022[2015-16]Status: DisposedITAT Delhi16 Dec 2024AY 2015-16

Bench: Pradip Kumar Kedia & Shri Anubhav Sharmaita No.2588/Del/2022 (Assessment Year : 2013-14) Ita No.2590/Del/2022 (Assessment Year : 2015-16) Ita No.2592/Del/2022 (Assessment Year : 2017-18) Rnb Infrastructure Pvt. Ltd. Vs. Dcit, Rnb House, 1, Shivaji Enclave, Central Circle-32, Main Road, Near Raja Garden, Opp. New Delhi Mother Dairy, New Delhi-110027 Pan No. Aadcr0962Q (Appellant) (Respondent) Assessee By Shri Ved Jain, Adv. & Sh. Aman Garg, Ca Revenue By Ms. Suman Malik, Cit-Dr Date Of Hearing: 18.09.2024 Date Of Pronouncement: 16.12.2024 Order Per Pradip Kumar Kedia, Am : The Captioned Appeals Filed By The Assessee Against The Respective Orders Passed Under S. 250 Of The Income Tax Act, 1961 (The Act) By The Ld.Cit(A) Is Tabulated Hereunder:-

Section 1Section 153A

course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies ... course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies

Rnb Infrastructure Pvt Ltd, New Delhi vs. DCIT Central Circle -32, New Delhi

In the result, captioned appeals of the assessee are allowed

ITA 2589/DEL/2022[2014-15]Status: DisposedITAT Delhi16 Dec 2024AY 2014-15

Bench: Pradip Kumar Kedia & Shri Anubhav Sharmaita No.2588/Del/2022 (Assessment Year : 2013-14) Ita No.2590/Del/2022 (Assessment Year : 2015-16) Ita No.2592/Del/2022 (Assessment Year : 2017-18) Rnb Infrastructure Pvt. Ltd. Vs. Dcit, Rnb House, 1, Shivaji Enclave, Central Circle-32, Main Road, Near Raja Garden, Opp. New Delhi Mother Dairy, New Delhi-110027 Pan No. Aadcr0962Q (Appellant) (Respondent) Assessee By Shri Ved Jain, Adv. & Sh. Aman Garg, Ca Revenue By Ms. Suman Malik, Cit-Dr Date Of Hearing: 18.09.2024 Date Of Pronouncement: 16.12.2024 Order Per Pradip Kumar Kedia, Am : The Captioned Appeals Filed By The Assessee Against The Respective Orders Passed Under S. 250 Of The Income Tax Act, 1961 (The Act) By The Ld.Cit(A) Is Tabulated Hereunder:-

Section 1Section 153A

course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies ... course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies

Rnb Infrastructure Pvt Ltd, Delhi vs. DCIT, Central Circle -32, Delhi

In the result, captioned appeals of the assessee are allowed

ITA 2588/DEL/2022[2013-14]Status: DisposedITAT Delhi16 Dec 2024AY 2013-14

Bench: Pradip Kumar Kedia & Shri Anubhav Sharmaita No.2588/Del/2022 (Assessment Year : 2013-14) Ita No.2590/Del/2022 (Assessment Year : 2015-16) Ita No.2592/Del/2022 (Assessment Year : 2017-18) Rnb Infrastructure Pvt. Ltd. Vs. Dcit, Rnb House, 1, Shivaji Enclave, Central Circle-32, Main Road, Near Raja Garden, Opp. New Delhi Mother Dairy, New Delhi-110027 Pan No. Aadcr0962Q (Appellant) (Respondent) Assessee By Shri Ved Jain, Adv. & Sh. Aman Garg, Ca Revenue By Ms. Suman Malik, Cit-Dr Date Of Hearing: 18.09.2024 Date Of Pronouncement: 16.12.2024 Order Per Pradip Kumar Kedia, Am : The Captioned Appeals Filed By The Assessee Against The Respective Orders Passed Under S. 250 Of The Income Tax Act, 1961 (The Act) By The Ld.Cit(A) Is Tabulated Hereunder:-

Section 1Section 153A

course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies ... course of assessment proceedings. During the assessment proceedings ample opportunities were given to the assessee to discharge its onus to substantiate the genuineness of the transactions. However, no plausible explanation was given in this regard at that time. However, the documents now being filed before your good self and replies

Abhaykumar Sevantilal Sanghavi, Deesa vs. The ACIT, Circle- Palanpur, Palanpur

Accordingly, these grounds are dismissed as infructuous

ITA 1368/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad13 Dec 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1367/Ahd/2024 & 1368/Ahd/2024 िनधा"रण वष" /Assessment Years :2016-17 & 2017-18 Respectively Abhaykumar Sevantilal Acit Circle, Palanpur बनाम/ Sanghavi [Old Jurisdiction-Circle, V/S. Sanghavi Brothers Palanpur. 1St Floor, Swastik Bldg New Jurisdiction-Circle, Nr. City Police Station Gandhinagar.] Nr. Dena Bank, Main Bazar Deesa – 385 535 (Gujarat) "थायी लेखा सं./Pan: Afbps 1660 L (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Mehul Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/12/2024 घोषणा की तारीख /Date Of Pronouncement: 13/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: Both These Appeals Preferred By The Assessee Pertain To The Assessment Years (Ays) 2016-17 & 2017-18. Since The Issues Involved Are Common & Connected, They Were Heard Together & Are Being Disposed Of By This Consolidated Order. The Appeals Arise Out Of The Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”] Under Section 250 Of The

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 115BSection 143(1)Section 143(3)Section 14ASection 23(4)Section 250Section 68

formal documentation, such as a gift deed. The CIT(A) sustained the disallowance, concluding that the creditworthiness of the donor and the genuineness of the transaction were not established. However, the evidence submitted before us, including the signed confirmation, cash book, and ITR of the donor, adequately addresses these concerns ... relationship of the donor with the assessee, the sufficiency of cash balance in the donor’s hands, and the established creditworthiness and genuineness of the transaction, we find no justification to sustain the addition made by the AO and upheld by the CIT(A). 30. The addition of Rs.10

Abhaykumar Sevantilal Sanghavi, Deesa vs. Old Jurisdiction- Circle, Palanpur New Jurisdiction-Circle, Gandhinagar

Accordingly, these grounds are dismissed as infructuous

ITA 1367/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad13 Dec 2024AY 2016-17

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1367/Ahd/2024 & 1368/Ahd/2024 िनधा"रण वष" /Assessment Years :2016-17 & 2017-18 Respectively Abhaykumar Sevantilal Acit Circle, Palanpur बनाम/ Sanghavi [Old Jurisdiction-Circle, V/S. Sanghavi Brothers Palanpur. 1St Floor, Swastik Bldg New Jurisdiction-Circle, Nr. City Police Station Gandhinagar.] Nr. Dena Bank, Main Bazar Deesa – 385 535 (Gujarat) "थायी लेखा सं./Pan: Afbps 1660 L (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Mehul Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/12/2024 घोषणा की तारीख /Date Of Pronouncement: 13/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: Both These Appeals Preferred By The Assessee Pertain To The Assessment Years (Ays) 2016-17 & 2017-18. Since The Issues Involved Are Common & Connected, They Were Heard Together & Are Being Disposed Of By This Consolidated Order. The Appeals Arise Out Of The Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”] Under Section 250 Of The

For Appellant: Shri Mehul Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 115BSection 143(1)Section 143(3)Section 14ASection 23(4)Section 250Section 68

formal documentation, such as a gift deed. The CIT(A) sustained the disallowance, concluding that the creditworthiness of the donor and the genuineness of the transaction were not established. However, the evidence submitted before us, including the signed confirmation, cash book, and ITR of the donor, adequately addresses these concerns ... relationship of the donor with the assessee, the sufficiency of cash balance in the donor’s hands, and the established creditworthiness and genuineness of the transaction, we find no justification to sustain the addition made by the AO and upheld by the CIT(A). 30. The addition of Rs.10

Shri Aijaz Abdul Sattar Malkani, Mumbai vs. Income Tax Office -Ward 9(1)(2), Mumbai

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

ITA 4044/MUM/2024[2007-08]Status: DisposedITAT Mumbai13 Dec 2024AY 2007-08

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am Shri. Aijaz Abdul Sattar Malkani Income Tax Officer, Ward 9(1)(2) 1303, Malkani Tower, Bandivali Hill Aaykar Bhavan, Mumbai – 400021. Vs. Road, Jogeshwari West, Mumbai – 400102. Pan/Gir No. Affpm4967G (Assessee) : (Respondent) Assessee By : Shri. Prakash Jhunjhunwala Respondent By : Shri. Pravin Salunkhe, Sr. Dr Date Of Hearing : 12.12.2024 Date Of Pronouncement : 13.12.2024 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2007-08. 2. The Assessee Has Challenged The Addition Of Rs. 11,34,000/- Made U/S. 68 Of The Act Towards Cash Deposited In The Assessee’S Bank Account. 3. Brief Facts Of The Case Are That The Assessee Is An Individual & Is A Partner In The Firm M/S. A. M. Enterprises Which Is Engaged In The Business Of Builders & Developers & Is Also A Director In M/S. Curio Finance & Investments Pvt. Ltd. The Assessee Had Filed His Return Of Income Dated 26.04.2008, Declaring Total Income At Rs. Nil After Claiming

For Appellant: Shri. Prakash JhunjhunwalaFor Respondent: Shri. Pravin Salunkhe, Sr. DR
Section 143(3)Section 250Section 68

operative Bank Ltd. Jogeshwari (West), Branch on the ground that the assessee has failed to prove the identity, creditworthiness of the parties and genuineness of the transaction with supporting documentary evidence. 4. The assessee was in appeal before the first appellate authority, who vide order dated 02.02.2013 upheld the addition

ACIT Central Circle-1(2), Hyderabad vs. Satty and Associates, Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 236/HYD/2022[2016-17]Status: DisposedITAT Hyderabad12 Dec 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.162 & 163/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2015-16 & 2018-19) Satty & Associates Vs. Assistant Commissioner Hyderabad Of Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.236/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2016-17) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) Cross Objection No.13/Hyd/2022 (Arising Out Of Ita No.236/Hyd/2022) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S Rama Rao, Ar (Appeared Through Virtual Mode)& Ms.S.Sandhya, Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 03/12/2024 घोर्णध की तधरीख/Date Of 12/12/2024 Pronouncement:

For Appellant: Shri S Rama Rao, ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 153A

without appreciating the fact that the appellant has filed all evidence including confirmation letter from the partners to prove identity of the partners, genuineness of the transactions and creditworthiness of the partners. The learned Counsel for the assessee further referring to the decision of Hon'ble High Court of Telangana

Satty and Associates, Hyderabad vs. ACIT, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 163/HYD/2022[2018-19]Status: DisposedITAT Hyderabad12 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.162 & 163/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2015-16 & 2018-19) Satty & Associates Vs. Assistant Commissioner Hyderabad Of Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.236/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2016-17) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) Cross Objection No.13/Hyd/2022 (Arising Out Of Ita No.236/Hyd/2022) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S Rama Rao, Ar (Appeared Through Virtual Mode)& Ms.S.Sandhya, Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 03/12/2024 घोर्णध की तधरीख/Date Of 12/12/2024 Pronouncement:

For Appellant: Shri S Rama Rao, ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 153A

without appreciating the fact that the appellant has filed all evidence including confirmation letter from the partners to prove identity of the partners, genuineness of the transactions and creditworthiness of the partners. The learned Counsel for the assessee further referring to the decision of Hon'ble High Court of Telangana

Satty and Associates, Hyderabad vs. Assistant Commissioner of Income Tax, Central Circle-1(2), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 162/HYD/2022[2015-16]Status: DisposedITAT Hyderabad12 Dec 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.162 & 163/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2015-16 & 2018-19) Satty & Associates Vs. Assistant Commissioner Hyderabad Of Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.236/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2016-17) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) Cross Objection No.13/Hyd/2022 (Arising Out Of Ita No.236/Hyd/2022) Assistant Commissioner Of Satty & Associates Hyderabad Income Tax [Pan : Aawfs8350D] Central Circle-1(2) Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S Rama Rao, Ar (Appeared Through Virtual Mode)& Ms.S.Sandhya, Ar रधजस् व द्वधरध/Revenue By: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 03/12/2024 घोर्णध की तधरीख/Date Of 12/12/2024 Pronouncement:

For Appellant: Shri S Rama Rao, ARFor Respondent: Shri Srinath Sadanala, DR
Section 132Section 153A

without appreciating the fact that the appellant has filed all evidence including confirmation letter from the partners to prove identity of the partners, genuineness of the transactions and creditworthiness of the partners. The learned Counsel for the assessee further referring to the decision of Hon'ble High Court of Telangana