“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

Aura Gold Pvt. Ltd., Delhi vs. ITO, Ward-3(4), Delhi

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

ITA 2435/DEL/2024[2012-13]Status: DisposedITAT Delhi16 Jun 2025AY 2012-13

Bench: Shri Vimal Kumar & Shri Brajesh Kumar Singh[Assessment Year: 2012-13] Aura Gold Pvt. Ltd. Income Tax Officer, Shop No.2, First Floor, Ward-3(4), 1164, Kucha Mahajani, Vs Room No.381, C.R. Building, Chandni Chowk, New Delhi-110002 Delhi-110006 Pan-Aaica9325K Assessee Revenue

Section 143(3)Section 147Section 68

sent through speed post came back to the office of the AO. Therefore, in given facts of the case, the identity, creditworthiness and genuineness of the transaction were not established by the assessee in the reassessment proceedings, which is an independent proceeding, as there was an information by the Investigation ... during the remand proceedings as discussed above. However, as noted by the AO in the remand report, the details regarding identity, creditworthiness and genuineness of the transactions were submitted by eleven subscribers during the original assessment proceedings, which is on record and the same needs to be further enquired

Income Tax Officer, Ward 1(1)(2), Dehradun vs. Mahalaxmi Buildwell, Dehradun

Appeal is dismissed in above terms

ITA 99/DDN/2023[2015-16]Status: DisposedITAT Dehradun13 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh(Through Video Conferencing) Assessment Year: 2015-16 Income Tax Officer, Vs. Mahalaxmi Buildwell, Ward-1(1)(2), 118, Subhash Road, Dehradun Dehradun Pan :Aazfm1835G (Appellant) (Respondent) Assessee By Sh. Mayank Kumar Aggarwal, Ca Department By Sh. A.S. Rana, Sr. Dr

Section 144Section 147Section 148Section 68

During the appellate proceedings, the appellant firm was asked to prove the identity &creditworthiness of the creditor and genuineness of the transaction along with supporting documentary evidences. Accordingly, the appellant firm filed the written submissions along with supporting documents. The same is discussed herewith as under: 5.4.1. Anil Sharma ... Rs.7,99,570/- for the A.Y. 2015-16. Thus the creditor has proved its identity & 3 | P a g e creditworthiness and genuineness of the transaction along with supporting documentary evidences. 5.4.2. Anil Sharma:- During the year under consideration, the creditor gave loan of Rs.90,00,000/- to the appellant

Santosh Agrawal, Chattisgarh vs. Deputy Commissioner of Income-Tax, Central Cirlce-1, Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 150/VIZ/2025[2006-07]Status: DisposedITAT Visakhapatnam13 Jun 2025AY 2006-07

Bench: Shri Veeravalli Durga Rao, Hon’Ble

Section 127Section 143(1)Section 143(2)Section 153ASection 245C(1)Section 245D

family members on 06.01.2012. Ld. AO observed that assessee failed to discharge the onus of proving the creditworthiness, identity and genuineness of the transactions and therefore added a sum of Rs. 8,51,91,388/- as unexplained cash credit under section 68 of the Act. 8. Further, it was also ... have come to light. He also stated that the assessee has failed to fulfil the onus cast upon him to prove the genuineness of the transaction and creditworthiness and identity of the investors to the satisfaction of the Ld. AO as held by the Hon’ble Page

Ashok Kumar Agrawal, Visakhapatnam vs. Deputy Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 136/VIZ/2025[2006-07]Status: DisposedITAT Visakhapatnam13 Jun 2025AY 2006-07

Bench: Shri Veeravalli Durga Rao, Hon’Ble

Section 127Section 143(1)Section 143(2)Section 153ASection 245C(1)Section 245D

Anita Lahu Ghadge, Mumbai vs. Circle41(1)(1), Mumbai

In the result, all the grounds of appeal preferred by the assessee fail and the appeal is dismissed

ITA 2623/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Jun 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Prabhash Shankaranita Lahu Ghadge, V/S. Assistant Commissioner Of Swapnapurti, 33-D, Kamgar Income Tax, Circle – 26(1), बनाम Chs Ltd., S.G. Barve Marg, Kautilya Bhavan, Bandra Near Nandkeshwar Mandir, Kurla Complex, Bandra Kamgar Nagar, Kurla East, (East), Mumbai – 400051, Mumbai–400024, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Afqpg3328A Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Sanjay Nikam, ARFor Respondent: Shri Aditya Rai (Sr. DR)

Section 143(3)

operative Bank Ltd. account of Shri J. M. Shah. However, given the availability of banking records, Form 26AS, and other supporting documents, the genuineness of the transaction stands fully established, and any inference drawn solely from his denial is unwarranted. Given that the payment has been properly accounted ... onus by furnishing the TDS certificate, banking records, and payment proof through proper banking channels. In light of this documentary evidence, the genuineness of the transaction stood established. 4.1 As regard other expenses, it was contented that the Ld. A.O. has disallowed 20% of the total vehicle expenses amounting

Scraft Products Pvt Ltd, New Delhi vs. ACIT Circle-22(2), New Delhi

In the result, the Appeal of the Assessee is partly allowed for

ITA 2697/DEL/2019[2010/11]Status: DisposedITAT Delhi13 Jun 2025

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalscraft Products Pvt. Ltd. Vs. Acit D-28, South Extension Circle-22(2) Part-1, New Delhi New Delhi Pan: Aalcs4578F Appellant Respondent Assessee By Dr. Rakesh Gupta, Advocate, Shri Somil Aggarwal, Advocate & Shri Deepesh Garg, Advocate Revenue By Sh. Mahesh Kumar, Cit (Dr) Date Of Hearing 27/05/2025 Date Of Pronouncement 13/06/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, New Delhi [‘Ld. Cit(A)’

Section 143(1)Section 147Section 148Section 68Section 69

that the matter was getting time barred. The Assessee has produced the documentby way of additional evidence to prove the identity, creditworthiness and genuineness of the transaction after making extensive efforts and regular fellow ups from the parties. 4 Scraft Products Pvt. Ltd. Vs. ACIT 7. Considering the above facts

K.D.Singh Poultries Private Ltd, Ranchi vs. ITO WD-1(5), Ranchi

In the result, appeal of the assessee is allowed

ITA 112/RAN/2018[10-11]Status: DisposedITAT Ranchi12 Jun 2025

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayk.D. Singh Poultries Private Limited, I.T.O., South Samaj Street, H.B. Road, Ward 1(5), Vs. Ranchi-834001. Ranchi. Pan No. Aadck 1696 C Appellant/ Assessee Respondent/ Revenue

money was returned, but unfortunately, now it is too late. As the assessee has substantially proved the identity, creditworthiness and genuineness of the transactions from the assessment order itself, the addition as made by the Assessing Officer and as confirmed by the ld. CIT(A) stands deleted

Urmila Kishan, Angul vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC)

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

ITA 191/CTK/2025[2018-19]Status: DisposedITAT Cuttack12 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(3)Section 250Section 68

showing receipt and payment respectively. Confirmations of receipt of repayment have been furnished. Hence the Assessee has proved the identity of the lenders, genuineness of the transactions and the capacity of the party who had given the loan amount. In general practice of the business, appellant takes loans and repays

ACIT, Circle-1(1), Rajkot vs. Sunshine Tiles Company Pvt. Ltd., Morbi

In the result, appeal filed by the revenue is dismissed

ITA 649/RJT/2024[2011-12]Status: DisposedITAT Rajkot12 Jun 2025AY 2011-12

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 649 /Rjt/2024 ("नधा"रण वष"/Assessment Year: (2011-12) Asstt. Commissioner Of Income Sunshine Tiles Company Pvt. Tax, Cir-1(1), Rajkot Ltd. Vs. Room No. 502, Aayakar Bhavan, S. No. 150 160/P1, B/H Sunhil Race Course Ring Road, Ceramics 8-A, National Highway, Rajkot – 360001 Rajkot – 360001 [Pan No.: Aancs3264L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)Section 68

paid to the said depositor, considering these facts and evidences, we find that assessee fully discharged his onus to prove identity, creditworthiness, and genuineness of the transaction. 13. We note that the assessing officer has stated in para 11 of the assessment order that the assessee did not produce copies ... primary onus lies on the assessee to prove the identity of the depositors, its capacity to advance the money and the genuineness of the transaction. In the present case, as the promoters were not produced before him, the A.O. held that the onus has not been properly discharged by assessee

Chemangattu Jose John, Kottayam vs. The Deputy Commissioner of Income Tax, Circle International Taxation, Tvm

In the result, the appeal of the assessee is allowed

ITA 58/COCH/2025[2015-2016]Status: DisposedITAT Cochin12 Jun 2025AY 2015-2016

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaassessment Years: 2015-16 Chemangattu Jose John Dcit, Circle International V. Taxation, Tvm Chemangattu House, Koodalloor Post, Meenachil Taluk, Kottayam, Kerala 686595. Pan : Atxpj2649R. (Appellant) (Respondent) Appellant By : Shri R Krishnan, Ca Respondent By : Shri Suresh Sivanandan, Irs, Cit-Dr. Date Of Hearing : 03.06.2025 Date Of Pronouncement : 12.06.2025 O R D E R Per Sonjoy Sarma: This Appeal Is Filed By The Assessee Against The Order Dated 22.11.2024 Passed By The Dcit Circle Intl. Txn, Tvm (Hereinafter Referred To As ‘Cit(A)’] U/S 147 R.W.S 144C(13) Of The Income Tax Act (‘Act’) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Are That During The Relevant Assessment Year, The Assessee Had Sold Two Agricultural Properties Totaling To Rs.15,59,000/-. The Actual Sale Consideration Was Rs.34,00,000/- & However, As Per Registered Deed, The Sale Consideration Was Rs.15,59,000 & Balance Rs.18,41,000/- Remains Unexplained. The Assessing Officer Made An Addition Of 2 Chemangattu Jose John Rs.18,41,000/- U/S 69A Of The Act As The Assessee Failed To Give Satisfactory Reply Before Him.

For Appellant: Shri R Krishnan, CAFor Respondent: Shri Suresh Sivanandan, IRS, CIT-DR

Section 147Section 69Section 69A

disputed that the monies were reached through normal banking channel and once the assessee has proved the identity of the buyer, genuineness of the transaction and source of fund, the initial burden stands discharged. The revenue has not brought any record showing the consideration exceeded Rs.34,00,000/- for that

Baiju Lekshmanan, Kollam vs. ITO, Ward 1 & Tps, Alappuzha

In the result, the appeal of the assessee is dismissed

ITA 144/COCH/2025[2017-18]Status: DisposedITAT Cochin12 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarmaassessment Years: 2017-18 Baiju Lekshmanan Ito, Ward-1 & Tps, V. Alappuzha Marackasseril, Atiramthengu, Alumpeedika Po, Prayar South, Kollam – 690547. Pan : Ambpl8921A. (Appellant) (Respondent) Appellant By : Shri Akhil Shaji, Advocate Respondent By : Smt. Leena Lal, Snr Ar. Date Of Hearing : 03.06.2025 Date Of Pronouncement : 12.06.2025 O R D E R Per Sonjoy Sarma: This Appeal Is Filed By The Assessee Against The Order Dated 27.11.2024 By The National Faceless Appeal Centre (Hereinafter Referred To As ‘Cit(A)’] For The Assessment Year 2017–18. 2. The Registry Has Informed That The Appeal Filed By The Assessee Is Barred By Limitation By 17 Days. An Application Seeking Condonation Of Delay For 17 Days Has Been Filed By The Assessee Explaining Reasons For Such Delay. We, After Considering The Application For Condoning The Delay, Condone The Delay & Admit The Appeal For Adjudication.

For Appellant: Shri Akhil Shaji, AdvocateFor Respondent: Smt. Leena Lal, Snr AR

Section 133(6)Section 139Section 143(2)Section 147Section 69A

Though the assessee claims that cash deposits were received out of fish sales, there is no proof to substantiate his claim. The genuineness of the transaction, the identity of the buyers and the creditworthiness of the transactions remain unexplained." Accordingly the AO passed Order u/s 147 r.w.s. 144B ... Baiju Lekshmanan (d) It is ample clear that the appellant does not have any evidence/proof to substantiate the submissions made by him. The genuineness of the transaction, the identity of the buyers and the creditworthiness of the transactions remain unexplained. Hence, the addition made by the A.O. is upheld

Mohan Dagadu Chougale, Kolhapur vs. ACIT, Central Circle, Kolhapur

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

ITA 1312/PUN/2024[2020-2021]Status: DisposedITAT Pune12 Jun 2025AY 2020-2021

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Mohan Dagadu Chougale Acit, Central Circle, C/O Kapil Dugdhalaya & Sweet Kolhapur Vs. Mart, 3068, A Ward, Kapiltirth Market, Kolhapur – 416002 Pan: Acwpc0051B (Appellant) (Respondent) Assessee By : S/Shri Nikhil S Pathak & Mayuresh Doshi Department By : Smt. Shraddha Nichal Date Of Hearing : 30-04-2025 Date Of Pronouncement : 12-06-2025 O R D E R

For Appellant: S/Shri Nikhil S Pathak &For Respondent: Smt. Shraddha Nichal

Section 115BSection 131Section 133ASection 143(3)Section 40A(3)Section 68Section 69Section 69C

During the course of assessment proceedings the Assessing Officer asked the assessee to prove the identity and creditworthiness of the above parties and genuineness of the transactions. In response to the same, the assessee stated that he had provided the PAN numbers to prove their identity and the bank accounts ... assessee to prove the genuineness of the transactions. However, in absence of production of the persons or their confirmation letters or bank statements of the above persons, the Assessing Officer held that the assessee could not prove the creditworthiness of the said persons. He, therefore, invoking the provisions of section

Ms. Allied Trade Links, Guwahati vs. ACIT Cir-2, Guwahati

In the result the appeal is allowed for statistical purposes

ITA 150/GTY/2023[2017-18]Status: DisposedITAT Guwahati11 Jun 2025AY 2017-18

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 143(3)Section 250Section 69A

Rs.39,94,846/- allowing relief of Rs.5,39,554/- to the assessee. 5. As regards the loan of Rs.10 lakhs, the creditworthiness and genuineness of the transaction of the loan along with the identity of the I.T.A. No.: 150/GTY/2023 Assessment Year: 2017-18 M/s. Allied Trade Links. creditor were established

Paras Rameshchandra Doshi, Rajkot vs. The PCIT - 1, Rajkot

ITA 280/RJT/2024[2013-14]Status: DisposedITAT Rajkot11 Jun 2025AY 2013-14

Section 115BSection 132Section 133ASection 139(1)Section 143(2)Section 147Section 148Section 263Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN

Income Tax Officer-3(1), Kanpur vs. Shri Arvind Kumar Gupta, Kanpur

In the result, the appeal is held to be allowed for statistical purposes

ITA 174/LKW/2020[2015-16]Status: DisposedITAT Lucknow11 Jun 2025AY 2015-16

Bench: SH.KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: NoneFor Respondent: Sh. Sanjeev Krishna Sharma, Addl CIT (DR)

Section 143(3)Section 250Section 268A

mere filing of purchase bills, demat account, contract notes and details of share consideration and STT paid are sufficient to explain the genuineness of the transaction. The Hon Kolkata High Court in dealing with a similar case in PCIT vs Swati Bajaj (2022) 139 11 Sh. Arvind Kumar Gupta ... assessees were not named in the report of the investigation wing , once they made a claim for exemption , they had to prove the genuineness of the transaction and the genuineness could not be proved only with reference to documents submitted by them but with reference to the fact that

Rahul Nemgonda Patil, Kolhapur vs. Income Tax Officer, Ichalkaranji

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

ITA 2522/PUN/2024[AY 2013-14]Status: DisposedITAT Pune11 Jun 2025

For Appellant: Department byFor Respondent: Date of hearing

Section 142(1)Section 144BSection 147Section 148Section 68

gifts, the appellant should have submitted the PAN details, confirmation of accounts from the donor, documents to prove the creditworthiness and genuineness of the transaction. For the agricultural income, the evidence of land holding and crop production details need to be submitted by the appellant. Mere statement that in order

Deputy Commissioner of Income Tax, Central Circle 27, Jhandewalan vs. Air Charter Services Pvt. Ltd, New Delhi

Appeal of the Revenue is dismissed

ITA 4743/DEL/2024[2014-15]Status: DisposedITAT Delhi11 Jun 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.4743, 4736 और4742/िद"ी/2024(िन.व. 2014-15 से 2016-17)

For Appellant: NoneFor Respondent: Shri Ashish Tripathi, Sr.DR

Section 133(6)Section 147Section 37Section 37(1)Section 44A

Total 3,32,86,216/- All the aforesaid creditors replied to notice issued by AO and confirmed the transaction. However, the AO suspected genuineness of the transaction, hence, rejected assessee’s contentions and made addition of the aforesaid amount. The assessee carried the issue in appeal before the CITA ... there was no sign board on the premises to establish commercial activity. This fact raised suspicion in the mind of AO regarding the genuineness of the transaction. It is also an undisputed fact that the assessee had deducted tax at source on the payments made to be aforesaid parties

Deputy Commissioner of Income Tax, Central Circle 27, Jhandewalan vs. Air Charter Services Private Limited, Room No

Appeal of the Revenue is dismissed

ITA 4742/DEL/2024[2016-17]Status: DisposedITAT Delhi11 Jun 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.4743, 4736 और4742/िद"ी/2024(िन.व. 2014-15 से 2016-17)

For Appellant: NoneFor Respondent: Shri Ashish Tripathi, Sr.DR

Section 133(6)Section 147Section 37Section 37(1)Section 44A

DCIT, Jhandewalan Extension, New Delhi vs. Air Charter Services Pvt. Ltd., Delhi

Appeal of the Revenue is dismissed

ITA 4736/DEL/2024[2015-16]Status: DisposedITAT Delhi11 Jun 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Amitabh Shuklaआअसं.4743, 4736 और4742/िद"ी/2024(िन.व. 2014-15 से 2016-17)

For Appellant: NoneFor Respondent: Shri Ashish Tripathi, Sr.DR

Section 133(6)Section 147Section 37Section 37(1)Section 44A

DCIT, New Delhi vs. M/S. Chadha Papers Ltd., Uttar Pradesh

The appeal of the assessee is allowed and the appeal of the revenue is dismissed

ITA 5213/DEL/2015[2012-13]Status: DisposedITAT Delhi11 Jun 2025AY 2012-13

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Dcit, Vs. M/S. Chadha Papers Ltd, Central Circle-29, Chadha Estate, Nainital New Delhi Road, Rampur, Bilaspur, Uttar Pradesh (Appellant) (Respondent) Pan: Aabcc3799C M/S. Chadha Papers Ltd, Vs. Dcit, Chadha Estate, Nainital Central Circle-29, Road, Rampur, Bilaspur, New Delhi Uttar Pradesh (Appellant) (Respondent) Pan: Aabcc3799C Assessee By : Shri Salil Kapoor, Adv Shri Anil Chachra, Adv Ms. Ananya Kapoor, Adv Revenue By: Ms. Pooja Swaroop, Cit (Dr) Date Of Hearing 13/05/2025 Date Of Pronouncement 11/06/2025

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Ms. Pooja Swaroop, CIT (DR)

Section 143(3)Section 14A

established by the scrutiny assessment order framed by the very same AO on 07.08.2014 for the year under consideration. The genuineness of the transaction of withdrawal of cash from the AOP and assessee‟s transaction with the AOP have been duly reflected in books of account by both the parties