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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

Tremendous Mining and Minerals Pvt Limited, Delhi vs. DCIT Central Circle-3, New Delhi

ITA 157/DEL/2023[2012-13]Status: DisposedITAT Delhi09 Jul 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2012-13 Tremendous Mining & Vs Dcit, Minerals Pvt. Ltd., Central Circle-3, Cabin No.-1, 1205, New Delhi. 89-Hemkunth Chamber, Nehru Place, New Delhi – 110 019. Pan: Aacct8840N (Appellant) (Respondent) Assessee By : Shri Ashwini Kumar, Ca & Shri Ankur Aggarwal, Ca Revenue By : Shri Kailash Dan Ratnoo, Cit-Dr Date Of Hearing : 01.05.2025 Date Of Pronouncement : 09.07.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 05.01.2023 Of The Commissioner Of Income-Tax (Appeals)-23, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Cit(A), Delhi-23/10303/2019-20 Arising Out Of The Appeal Before It Against The Order Dated 24.12.2019 Passed U/S 148 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Central Circle- 3, Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Ashwini Kumar, CA &For Respondent: Shri Kailash Dan Ratnoo, CIT-DR
Section 132Section 139Section 143(1)Section 143(3)Section 148Section 153A

Rs.10/- per share. At no point of time in any of the proceedings, the appellant or any entity was able to establish the genuineness of the transaction. Further, Jawahar Credit could not explain the transaction when opportunity was provided to them. If the transactions are genuine, in that case ... obligation to depose and state the facts. However, in this case, at no point of time any director appeared to explain the genuineness of the transaction. 12. M/s Jawahar Credits & Holdings Pvt. Ltd. has no creditworthiness to invest an amount of Rs,25,00,00,000/- in the appellant company

ITO, Ward-18(), New Delhi vs. Nivia Agencies Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1009/DEL/2021[2002-03]Status: DisposedITAT Delhi09 Jul 2025AY 2002-03

Bench: MS. MADHUMITA ROY (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142Section 143(1)Section 144Section 148Section 250(6)Section 68

during the previous year 2001-02 relevant to A.Y 2002-03 and invested in unquoted shares of other companies. To verify the genuineness of the transactions the Sh. Dinesh Kumar, ITI was deputed to make inquiries He has vide report dated 18 1 2006 reported as under- As directed

ITO Ward 4(4), New Delhi vs. Bharatpuria Finance & Investment Ltd, New Delhi

In the result, order of the CIT(A) on the issues raised before us by the Revenue in its appeal are upheld and appeal of the Revenue is dismissed

ITA 3513/DEL/2019[2013-14]Status: DisposedITAT Delhi09 Jul 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.3513/ िद"ी /2019 (िन.व. 2013-14) Income Tax Officer, Ward-4(4), R. No. 385A, 3Rd Floor, Cr Building, Ip Estate, ...... अपीलाथ"/Appellant New Delhi 110002 बनाम Vs. Bharatpuria Finance & Investment Ltd., C-4/164, Keshav Puram, Delhi 110035 ..... "ितवादी/Respondent Pan: Aaacb-3662-N Assessee By : Shri Ravi Saini, Managing Director Department By: Shri Ashish Tripathi, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 24/04/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 09/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-2, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 23.01.2019, For Assessment Year 2013-14. 2. Brief Facts Of The Case As Emanating From Records Are: The Assessee Is A Non Banking Finance Company. The Assessee Filed Its Return Of Income For The Impugned Assessment Year Declaring Nil Income & Claiming Current Year Loss Of Rs.4,02,609/-.

For Appellant: Shri Ravi Saini, Managing DirectorFor Respondent: Shri Ashish Tripathi, Sr. DR
Section 143(3)Section 68

credit. The AO has made addition for the reason that the assessee allegedly fail to prove identity and creditworthiness of the lender and genuineness of the transaction. The CIT(A) after considering the issue has given categorical finding that the assessee had taken unsecured loan of Rs.25,00,000/- from

Gdg Educational Trust, Sohna vs. Addl. CIT, Range- 1, Gurgaon

In the result, the appeal being ITA No

ITA 1057/DEL/2019[2013-14]Status: DisposedITAT Delhi09 Jul 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Amit Goel, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 234ASection 271(1)(c)Section 37(1)

proved that the expenses were wholly spent for the purpose of business and he submitted that since assessee has not proved the genuineness of the transactions, it is disallowable u/s 37(1) of the Act. He submitted that considering the facts available on record, ld. CIT (A) has already given

Gdg Educational Trust, Sohna vs. Addl. CIT, Range- 1, Gurgaon

In the result, the appeal being ITA No

ITA 1056/DEL/2019[2012-13]Status: DisposedITAT Delhi09 Jul 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Amit Goel, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 234ASection 271(1)(c)Section 37(1)

proved that the expenses were wholly spent for the purpose of business and he submitted that since assessee has not proved the genuineness of the transactions, it is disallowable u/s 37(1) of the Act. He submitted that considering the facts available on record, ld. CIT (A) has already given

Gdg Educational Trust, Sohna vs. Addl. CIT, Range- 1, Gurgaon

In the result, the appeal being ITA No

ITA 1055/DEL/2019[2011-12]Status: DisposedITAT Delhi09 Jul 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Amit Goel, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 234ASection 271(1)(c)Section 37(1)

proved that the expenses were wholly spent for the purpose of business and he submitted that since assessee has not proved the genuineness of the transactions, it is disallowable u/s 37(1) of the Act. He submitted that considering the facts available on record, ld. CIT (A) has already given

Gdg Educational Trust, Sohna vs. Addl. CIT, Range- 1, Gurgaon

In the result, the appeal being ITA No

ITA 1054/DEL/2019[2010-11]Status: DisposedITAT Delhi09 Jul 2025AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Amit Goel, AdvocateFor Respondent: Shri Om Prakash, Sr. DR
Section 234ASection 271(1)(c)Section 37(1)

proved that the expenses were wholly spent for the purpose of business and he submitted that since assessee has not proved the genuineness of the transactions, it is disallowable u/s 37(1) of the Act. He submitted that considering the facts available on record, ld. CIT (A) has already given

Himgiri Realtors Pvt. Ltd., New Delhi vs. ITO, Ward- 11(3), New Delhi

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

ITA 7080/DEL/2018[2012-13]Status: DisposedITAT Delhi09 Jul 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarhimgiri Realtors Private Limited, Vs. Ito, Ward 11 (3), Flat No.818, 8Th Floor, New Delhi. Devika Tower 6, Nehru Place, New Deli – 110 019. (Pan : Aabch6093E) (Appellant) (Respondent) Assessee By : Shri I.P. Bansal, Advocate Shri Vivek Bansal, Advocate Revenue By : Shri Dayainder Singh Sidhu, Cit Dr Date Of Hearing : 04.06.2025 Date Of Order : 09.07.2025 O R D E R Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-35, New Delhi [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 28.08.2018 For Assessment Year 2012-13 Raising Following Revised Grounds Of Appeal :- “1. That Under The Facts & Circumstances Of The Case, The Impugned Appeal Order Is Bad In Law, Illegal & In Violation Of Rudimentary Principal Of Contemporary Jurisprudence.

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 133(6)Section 142(1)Section 2(22)(e)Section 68

held that the transaction with Global Distributors Limited are sham transactions. Accordingly, he held that the assessee has not proved creditworthiness and genuineness of the transactions. Accordingly, he disallowed whole unsecured loan received from them u/s 68 of the Act. 11. Aggrieved with the above order, assessee is in appeal ... Aeren Group of companies and appellant company is one of the concerns of the. group. The appellant company has failed to prove the genuineness of the transactions between appellant company and M/s Global Distributors Ltd. Section 68 of the Income-Tax Act, 1961 provides that, where any sum is found

ACIT, New Delhi vs. M/S. New India City Developers Pvt. Ltd., New Delhi

In the result, appeal of the revenue is partly allowed

ITA 4804/DEL/2016[2011-12]Status: DisposedITAT Delhi09 Jul 2025AY 2011-12

Bench: MS. MADHUMITA ROY (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 142(1)Section 143(2)Section 250(6)Section 68

circumstances as explained above. In nutshell the assessing officer has gone to that extent that assessee failed to prove the Identity, Creditworthiness and genuineness of the transaction of credit appearing in the books of assessee. It is also observed by Ld. AO that mere filling of PAN, Copy ... held that if the AO is not satisfied with the documents filed by the assessee to prove the identity, credit worthiness and genuineness of the transactions as provided in section 68, then, the AO can exercise his powers conferred upon him under the IT Act to make further enquiries/investigations. From

ITO, New Delhi vs. M/S. Marathon Finlease Ltd., Delhi

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

ITA 4766/DEL/2016[2011-12]Status: DisposedITAT Delhi09 Jul 2025AY 2011-12

Bench: MS. MADHUMITA ROY (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(3)Section 14ASection 250(6)Section 68

received share capital of Rs.4,04,50,000/- from eighteen share applicants and thus, the AO asked the assessee to prove the genuineness of the transactions. The AO also observe that they are certain expenses claimed which was not properly explained by the assessee and it is further observed ... introduced in the garb of share application money/share capital by to appreciating the facts the assessee did not discharge its onus of prove genuineness of the transactions, identity and creditworthiness of investors? 3. Whether on the facts and circumstances of the case

Vital Care Private Limited, Vadodara vs. The Dy. CIT, Circle-2(1)(1), Vadodara

In the result, the appeal of the assessee is allowed

ITA 527/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad08 Jul 2025AY 2014-15

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2014-15

For Appellant: Ms. Rangoli Gada, C.AFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 142(1)Section 143(2)Section 68

income u/s 68 of the IT Act. The assessing officer believed that the assessee has failed to prove the identity, credit worthiness and genuineness of the transaction and could not substantiate the source of source of such transaction. The I.T.A No. 527/Ahd/2025 Vital Care Pvt. Ltd., A.Y. 2014-15 assessing

Pravin Jain, Kolkata vs. ITO, Ward 1(1), Jalpaiguri

In the result, apeal of the assessee is partly allowed for statistical

ITA 445/KOL/2025[2018-19]Status: DisposedITAT Kolkata08 Jul 2025AY 2018-19
For Appellant: Shri Amit Jaria, staff of the AR’s officeFor Respondent: Shri S.B.Chakraborthy, Sr.DR
Section 36(1)(iii)Section 37(1)Section 37(1)(iii)Section 68

assessee has failed to submit the requisite details, which could conclusively establish beyond doubt the identity and creditworthiness of the lenders and genuineness of the transaction. Similarly in respect of the disallowance u/s.37(1) of the Act, the same is in relation to the addition which has been made

ACIT-6(1)(1), Mumbai vs. Aditya Birla Sun Life Amc Ltd., Mumbai

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

ITA 792/MUM/2025[2020-21]Status: DisposedITAT Mumbai08 Jul 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailaditya Birla Sun Life Amc Ltd., Tower 1, Jupiter Mill Compound, 17Th Floor, One World Center, 841, Senapati Bapat Marg, ............... Appellant Mumbai - 400013 Pan : Aaacb6134D V/S

For Appellant: Shri Ronak DoshiFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 40

eligibility of assessee to claim deduction u/s. 80G of the Act, falling in chapter VIA of the Act. It is further observed that genuineness of the transactions and identity of the donees are also not under challenge. All the payments were made through proper banking channel and appropriate donation receipts

Aditya Birla Sun Life Amc Limited, Mumbai vs. Assessment Unit, Income-Tax Department, National Faceless Assessment Centre (NFAC), Delhi

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

ITA 494/MUM/2025[2020-21]Status: DisposedITAT Mumbai08 Jul 2025AY 2020-21

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Ronak DoshiFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 40

eligibility of assessee to claim deduction u/s.80G of the Act, falling in chapter VIA of the Act. It is further observed that genuineness of the transactions and identity of the donees are also not under challenge. All the payments were made through proper banking channel and appropriate donation receipts were

Dy. Commissioner of Income Tax, Mumbai vs. Shree Thirumalai Marketing & Investments Limited, Mumbai

In the result, both the appeals filed by the revenue in ITA Nos

ITA 474/MUM/2025[2023-14]Status: DisposedITAT Mumbai08 Jul 2025AY 2023-14

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Varun BrahmechaFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

that the assessee could not provide any supporting documentary evidence and explanation on the identity and creditworthiness of the share application money and genuineness of such transactions?" (iii) "Whether on the facts and circumstances of the case, the Ld. CIT(A) was right in not employing his powers that ... Supreme Court in examining in sufficient 3 and appropriate detail whether the 3 conditions of genuineness of the creditor, genuineness of the transaction and creditworthiness of the creditor stood satisfied in the credits purportedly received by the assessee from Mix. SM Commodity and Bullion Trading Pvt. Ltd?" 4. The brief

Dy. Commissioner of Income Tax (Central Circle)-2(3), Mumbai vs. Shree Thirumalai Marketing & Investments Limited, Mumbai

In the result, both the appeals filed by the revenue in ITA Nos

ITA 139/MUM/2025[2013-14]Status: DisposedITAT Mumbai08 Jul 2025AY 2013-14

Bench: BEFOR SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Varun BrahmechaFor Respondent: Shri Hemanshu Joshi, SR DR
Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 68

that the assessee could not provide any supporting documentary evidence and explanation on the identity and creditworthiness of the share application money and genuineness of such transactions?" (iii) "Whether on the facts and circumstances of the case, the Ld. CIT(A) was right in not employing his powers that ... Supreme Court in examining in sufficient 3 and appropriate detail whether the 3 conditions of genuineness of the creditor, genuineness of the transaction and creditworthiness of the creditor stood satisfied in the credits purportedly received by the assessee from Mix. SM Commodity and Bullion Trading Pvt. Ltd?" 4. The brief

Shri Gaurav Palriwal, Ranchi vs. ACIT Central Circle -1, Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 121/RAN/2024[2011-12]Status: DisposedITAT Ranchi07 Jul 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

Section 148Section 151Section 153A

assessee had produced all relevant documents such as demat account statement, bank statement showing purchase & sale, STT paid details etc to establish the genuineness of the transaction. 6. That there is no evidence with the revenue department which can directly allege that the assessee in person was involved in price

Smt Renu Palriwal, Kolkata vs. ACIT Central Circle-1, Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 66/RAN/2023[2013-14]Status: DisposedITAT Ranchi07 Jul 2025AY 2013-14

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

Section 148Section 151Section 153A

assessee had produced all relevant documents such as demat account statement, bank statement showing purchase & sale, STT paid details etc to establish the genuineness of the transaction. 6. That there is no evidence with the revenue department which can directly allege that the assessee in person was involved in price

Smt. Renu Palriwal, Kolkat vs. ACIT Central Circle-1, Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 65/RAN/2023[2011-12]Status: DisposedITAT Ranchi07 Jul 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

Section 148Section 151Section 153A

assessee had produced all relevant documents such as demat account statement, bank statement showing purchase & sale, STT paid details etc to establish the genuineness of the transaction. 6. That there is no evidence with the revenue department which can directly allege that the assessee in person was involved in price

Sri Kamal Kumar Palriwal, Kolkata vs. ACIT, Central Circle-1, Ranchi

In the result, all the captioned appeals of the assessee are allowed

ITA 64/RAN/2023[2011-12]Status: DisposedITAT Ranchi07 Jul 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 10 & 11/Ran/2023 (Assessment Year-2012-13 & 2013-14) Sri Vishal Palriwal, A.C.I.T., Ishatvam, Flat No. 801, 8Th Floor, Central Circle-1 Vs. Kanke Road, Ranchi-834008. Ranchi. Pan No. Ahnpp 0913 H Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 12/Ran/2023 (Assessment Year-2012-13) Sri Gaurav Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Aiapp 8110 E Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 13/Ran/2023 (Assessment Year-2013-14) Sri Saurav Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Kolkata. Ranchi. Pan No. Atcpp 9277 D Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 14/Ran/2023 (Assessment Year-2013-14) Smt. Priti Palriwal, A.C.I.T., Flat No. 701, 7Th Floor, Ishatvam, Central Circle-1 Vs. Behind Kanke Petrol Pump, Kanke Ranchi. Road, Ranchi-834008. Pan No. Amdpp 5673 K Appellant/ Assessee Respondent/ Revenue It(Ss)A No. 15/Ran/2023 (Assessment Year-2013-14) Smt. Renu Palriwal, A.C.I.T., Block No. 1, Flat No. 3C, Space Town Central Circle-1 Vs. Vip Road, Raghunathpur, Ranchi. Kolkata-700052 Pan No. Ajlpp 9129 K Appellant/ Assessee Respondent/ Revenue

Section 148Section 151Section 153A

assessee had produced all relevant documents such as demat account statement, bank statement showing purchase & sale, STT paid details etc to establish the genuineness of the transaction. 6. That there is no evidence with the revenue department which can directly allege that the assessee in person was involved in price