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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

Navansh Vinimay Pvt. Ltd., Kolkata vs. I.T.O., Ward - 8(2), Kolkata

In the result, the appeal of the assessee is dismissed

ITA 724/KOL/2022[2012-2013]Status: DisposedITAT Kolkata30 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143Section 143(2)Section 143(3)Section 147Section 148Section 151Section 250

involves three ingredients, namely, the proof regarding the identity of the share applicants, their creditworthiness to purchase the shares and the genuineness of the transaction as a whole". That is the approach adopted by Hon'ble Courts above all along. In the case of CIT v. United Commercial and Industrial ... confirmatory letters, or demonstrating that the transactions are done through the banking channels or even by filing the income tax assessment particulars. The genuineness of the transaction as a whole is thus a very important and critical factor in the examination of explanation of the assessee, as required under section

Govdappagouda Channabasangouda Patil, Hubli vs. Income Tax Officer, Ward-3(2), Hubli

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

ITA 1461/BANG/2024[2015-2016]Status: DisposedITAT Bangalore30 May 2025AY 2015-2016

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year :2015-16

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 143(1)Section 143(2)Section 143(3)Section 250Section 41Section 44ASection 68

this ground by observing that assessee was required to produce documents which could establish identity as well as creditworthiness of the creditors and genuineness of the transaction. Without the PAN, the genuineness of the transaction cannot be verifiable and accordingly was of the opinion that no interference is required

Jaguar Services Pvt Ltd, Mumbai vs. DCIT Circle 1(2)(1), Mumbai

ITA 113/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Jeet KamdarFor Respondent: Shri Rajendra Chandekar
Section 147Section 263

short ‘Witteneia') should not be made. In response, the Assessee filed a detailed submission vide Letter, dated 09/03/2024, to prove the genuineness of the transaction and also submitted sufficient supporting to substantiate the transaction carried out by the Assessee. Subsequently, the Assessing Officer passed the Assessment Order, dated 19/03/2024, under

DCIT-CC-4(3), Mumbai vs. Era Realtors Private Limited, Mumbai

In the result, the ground No

ITA 3096/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 May 2025AY 2013-14

Bench: Shri Pawan Singh, Hon'Bleshri Girish Agrawal, Hon'Ble

Section 132Section 143(2)Section 153ASection 254(1)Section 92C

determined ALP at Nill for the reasons that assessee was not able to justify the identity and creditworthiness of the investor companies and genuineness of the transaction on the issue of CCD to Thirdscroll Holding ted. As per section 92C(1)of the Income Tax Act. The TPO is required

Uday Vithal Nagpure, Mumbai vs. Assessing Officer, Mumbai

Appeal are treated as allowed for statistical purposes

ITA 2511/MUM/2023[2011-12]Status: DisposedITAT Mumbai30 May 2025AY 2011-12

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Kavita P. Kaushik
Section 144Section 147Section 250

advance such huge amount to the assessee. The onus was on the assessee to prove the creditworthiness of the said lender and the genuineness of the transaction which he has failed to do so. In view of the said facts a sum of Rs. 1,04,05,000/- is added

DCIT, Circle- 2, Meerut vs. Pioneer Fabricators Pvt. Ltd., Meerut

In the result, the Departmental appeal is dismissed and the assessee’s appeal is allowed

ITA 2555/DEL/2018[2013-14]Status: DisposedITAT Delhi30 May 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy[Assessment Year 2013-14] M/S Pioneer Fabricators (P) Dcit, Ltd. B-2, Saraswati Industrial Circle-2, Income Tax Office , Estate, Partapur, Vs Bhaisali Ground, Meerut (U.P.) Meerut, (U.P.) Pan-Aabcp3296R Appellant Respondent [Assessment Year 2013-14] Dcit, M/S Pioneer Fabricators (P) Ltd. B- Circle-2, Income Tax Office , 2, Saraswati Industrial Estate, Bhaisali Ground, Meerut Vs Partapur, (U.P.) Meerut, (U.P.) Pan-Aabcp3296R Appellant Respondent

Section 145(3)Section 68

Appellant u/s 68 of the Act, citing the reason that the Appellant failed to provide any satisfactory documents in support of creditworthiness and genuineness of the transaction and made Addition of Rs.60,15,000 on account of unsecured loans u/s 68 of the Act. 4.2. Further, Ld. AO rejected ... flow submitted on record. Further, there is no enquiry by the AO to link it with the company. Moreover, the identity, creditworthiness and genuineness of the transaction have been established by the appellant beyond doubt. The assessee placed reliance on following judicial precedents:- I. Commissioner of Income Tax vs Lovely

Income Tax Officer Ward Hingoli, Ward Hingoli (Camp at Parbhani) vs. Vishwas Agro Product Pvt Ltd, Parbhani

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

ITA 1566/PUN/2024[2017-18]Status: DisposedITAT Pune29 May 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Govind PrasadFor Respondent: Shri Milind Debaje – JCIT (Virtual)
Section 143(2)

view that, the amount of advance received against export cannot be treated as Interest free loan and since appellant has proved about the genuineness of the transactions, and submitted the documents submitted to Bank for extension of time and goods were exported later on and the advance was adjusted

Income Tax Officer, Kolkata vs. Venkatesh International Exim Pvt Ltd, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1456/KOL/2024[2013-14]Status: DisposedITAT Kolkata29 May 2025AY 2013-14

Bench: Shri Duvvuru RL Reddy (Vice President)

Section 143(2)Section 148Section 68

that onus of proving the identity and creditworthiness of the parties from whom the assessee received money and genuineness of such transaction is on the assessee. 2 Venkatesh International Exim Pvt. Limited (3) That the appellant craves leave to add any new ground or alter any of the grounds ... with whom the transaction was undertaken by the appellant and the date of transaction. In the absence of primary details to prove the genuineness of the transaction, the addition made by the Assessing Officer is without proper appreciation of facts and the Assessing Officer is directed to delete the addition

Khec (India) Pvt Ltd, Delhi vs. Income Tax Officer Ward 14(3), New Delhi, Delhi

In the result, the appeal of the assessee is allowed

ITA 3064/DEL/2024[2015-2016]Status: DisposedITAT Delhi29 May 2025AY 2015-2016

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2015-16 Khec (India) Pvt. Ltd. Vs. Income Tax Officer, C/O Kapil Goel Adv, Ward 14(3), F-26/124/Sector 7 Rohini New Delhi Delhi Pan No. Aabck8895K (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 153CSection 250Section 68Section 69C

record by the assessee, there is no doubt that the assessee has fulfilled its onus of.  Establishing the source of amount received.  Genuineness of the transaction and  Credit worthiness of the party. 30. The above submission clearly establish that the addition made by the Ld. AO is totally arbitrary, illegal

Dattatray Hanmantrao Desai, Karad vs. Principal Commissioner of Income Tax, Pune

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

ITA 1240/PUN/2024[2018-19]Status: DisposedITAT Pune28 May 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

For Appellant: Shri Ashok B NawalFor Respondent: Shri Amol Khairnar, CIT-DR
Section 143(3)Section 263Section 68

been explained. The documents available on records and the short comings/deficiencies pointed out do not establish the identity of the creditor, the genuineness of the transaction and the creditworthiness in terms of section 68 2 Amrut Kakaso 98,39,955/- ITR-V for AY No document in support of Kumbhar ... records. The documents available on records and the short comings / deficiencies pointed out do not substantiate the identity of the creditor, the genuineness of the transaction and the creditworthiness in terms of section 68 3 Vijay 3,00,00,000/- Unsigned copy of No document in support of Raghunath

ACIT-6(1)(2), Mumbai vs. J M Financial Properties and Holdings Limited, Mumbai

ITA 1396/MUM/2025[2014-15]Status: DisposedITAT Mumbai28 May 2025AY 2014-15

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dr.K. Shivaram Sr.AdvocateFor Respondent: Ms. Kavita P. Kaushik
Section 143(3)Section 250Section 28Section 36Section 36(1)(ii)Section 36(1)(iii)

Leave & License when the market value of the said Premises was INR.200 Crores. For the aforesaid reason the Assessing Officer doubted the genuineness of the transaction and concluded that the Assessee had suppressed facts and disturbed the financial position by artificially reducing profits. 9. In appeal before ... paper-book) 11. There is nothing on record to doubt the veracity of the documents furnished by the Assessee or to doubt the genuineness of the transaction. We note that the Assessee had explained that the higher amount of security deposit ensured comparatively lower rental expenses. Further, the Assessee

ACIT-6(1)(2), Mumbai vs. J M Financial Properties and Holdings Limited, Mumbai

ITA 1389/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 May 2025AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Dr.K. Shivaram Sr.AdvocateFor Respondent: Ms. Kavita P. Kaushik
Section 143(3)Section 250Section 28Section 36Section 36(1)(ii)Section 36(1)(iii)

Leave & License when the market value of the said Premises was INR.200 Crores. For the aforesaid reason the Assessing Officer doubted the genuineness of the transaction and concluded that the Assessee had suppressed facts and disturbed the financial position by artificially reducing profits. 9. In appeal before ... paper-book) 11. There is nothing on record to doubt the veracity of the documents furnished by the Assessee or to doubt the genuineness of the transaction. We note that the Assessee had explained that the higher amount of security deposit ensured comparatively lower rental expenses. Further, the Assessee

Scion Enterprises Private Limitd, Mumbai vs. ITO, Ward, 4(3)(4), Mumbai

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

ITA 5560/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 May 2025AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: NoneFor Respondent: Shri. Ram Krishn Kedia, (SR. DR.)
Section 115JSection 131Section 132Section 143(2)Section 143(3)Section 145(3)Section 145ASection 250Section 28

Tribunal inspite of several opportunities. The assessee has been non-compliant even before the lower authorities, where it has failed to prove the genuineness of the transaction by way of documentary evidence such as purchase 3 Scion Enterprises Pvt. Ltd. invoice, purchase orders, confirmation from sellers of goods, inward register

Colorado Chattels Pvt. Ltd., New Delhi vs. ITO, Ward-6(2), Delhi

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

ITA 3169/DEL/2024[2012-13]Status: DisposedITAT Delhi28 May 2025AY 2012-13

Bench: Shri S.Rifaur Rahman

For Appellant: Shri K.R. Manjani, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 148Section 151(1)Section 68

company are untraceable. He supported findings of the ld. CIT (A) that these companies are paper companies and assessee has not proved the genuineness of the transactions. Considered the rival submissions and material placed on record. I observed that the AO received certain information from the investigation wing and based

Ashok Kumar Grover, Ghaziabad vs. ITO Ward - 69(4), New Delhi

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

ITA 5809/DEL/2019[2015-16]Status: DisposedITAT Delhi28 May 2025AY 2015-16

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Nitin Goyal, CAFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 133Section 133(6)Section 143(1)Section 143(2)Section 186

unsecured loan of Rs.20 lakhs. He submitted that during assessment proceedings, assessee has submitted all the details to prove the identity, creditworthiness and genuineness of the transaction. He submitted that the assessee has already satisfied identity and creditworthiness of the lender. However, the AO and ld. CIT (A) rejected ... submissions of the assessee on the basis of genuineness of the transaction that too non-compliance of the lender as per the Companies Act. He submitted that as far as income-tax is concerned, the 6 assessee has already submitted all the relevant information from his side and proved

ITO, Ward-1(1), Moradabad vs. M.M.Construction, Moradabad

In the result only ground pressed by the assessee is allowed

ITA 2805/DEL/2019[2014-15]Status: DisposedITAT Delhi28 May 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2014-15

Section 144Section 145(3)Section 68

failure on the part of the assessee in discharging its primary onus of proving identity and creditworthiness of the suppliers and genuineness of the transactions of sundry creditors shown in the Balance Sheet as on 31.3.2014. (2) On the facts and in the circumstances of the case ... assessee by the Assessing officer for the reason that the assessee did not explain the identity and creditworthiness of the depositors and genuineness of the transactions during the assessment proceedings. The burden to prove identity, creditworthiness and genuineness of transactions lies with the assessee as the assessee failed

M.M.Construction, Moradabad vs. ITO, Ward-1(1), Moradabad

In the result only ground pressed by the assessee is allowed

ITA 2030/DEL/2019[2014-15]Status: DisposedITAT Delhi28 May 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2014-15

Section 144Section 145(3)Section 68

failure on the part of the assessee in discharging its primary onus of proving identity and creditworthiness of the suppliers and genuineness of the transactions of sundry creditors shown in the Balance Sheet as on 31.3.2014. (2) On the facts and in the circumstances of the case ... assessee by the Assessing officer for the reason that the assessee did not explain the identity and creditworthiness of the depositors and genuineness of the transactions during the assessment proceedings. The burden to prove identity, creditworthiness and genuineness of transactions lies with the assessee as the assessee failed

DCIT, Centraql Circle-28, New Delhi vs. Geemed Promoters P.Ltd, New Delhi

ITA 2242/DEL/2018[2011-12]Status: DisposedITAT Delhi28 May 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2011-12 Dcit, Vs Geemed Promoters P. Ltd., Central Circle-28, F-6, Second Floor, New Delhi. Vijay Chowk, Laxmi Nagar, New Delhi – 110 092. Pan: Aaecg1614P Co No.114/Del/2018 (Ita No.2242/Del/2018) Assessment Year: 2011-12 Geemed Promoters P. Ltd., Vs. Dcit, F-6, Second Floor, Central Circle-28, Vijay Chowk, New Delhi. Laxmi Nagar, New Delhi – 110 092. Pan: Aaecg1614P (Appellant) (Respondent) Assessee By : Shri Sachin Jain, Advocate Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 07.05.2025 Date Of Pronouncement : 28.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Revenue Against The Order Dated 15.01.2018 Of The Commissioner Of Income-Tax (Appeals)-29, New Delhi Co No.114/Del/2018 (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.298/16-17/Cit(A)-29 Arising Out Of The Appeal Before It Against The Order Dated 19.03.2014 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The Acit, Central Circle-28, New Delhi (Hereinafter Referred To As The Ld. Ao). The Assessee Has Filed Cross Objection. 2. The Revenue Has Taken The Following Grounds Of Appeal:- “1. That On The Facts & In The Circumstances Of The Case, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 10 Crore On Account Of (Paid - Up Share Capital, Share Premium & Security Premium) Credited In Its Books Of Accounts Ignoring The Fact That The Assessee Had Not Discharged Its Primary Onus To Establish The Identity & Creditworthiness Of The Creditors & Genuineness Of The Transaction During Assessment Proceedings.” 2. The Appellant Craves Leave To Add, Alter Or Amend Any/All Of The Grounds Of Appeal Before Or During The Course Of The Hearing Of The Appeal.”

For Appellant: Shri Sachin Jain, AdvocateFor Respondent: Shri Om Parkash, Sr. DR
Section 132Section 143(3)Section 153A

accounts ignoring the fact that the assessee had not discharged its primary onus to establish the identity and creditworthiness of the creditors and genuineness of the transaction during assessment proceedings.” 2. The appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during

M/S Pazhayangadi G Gold, Kannur vs. ITO Ward 1 & Tps, Kannur

In the result, the appeal by the assessee is dismissed

ITA 187/COCH/2023[2018-19]Status: DisposedITAT Cochin27 May 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhailassessment Year : 2018-19 Pazhayangadi G Gold, Ito, Ward-1& Tps, Eazhome Pazhayangadi, Kannur Kannur-670303 Vs. Pan : Aaufp9485G (Appellant) (Respondent) For Assessee : Shri Arun Raj S. Adv. For Revenue : Shri Sanjit Kumar Das, Cit-Dr (Heard In Hybrid Bench) Date Of Hearing : 25-03-2025 Date Of Pronouncement : 27-05-2025 O R D E R

For Appellant: Shri Arun Raj S. AdvFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 142(1)Section 143Section 143(1)Section 143(2)Section 143(3)Section 263Section 270ASection 271ASection 68Section 69

computerised receipts in respect of old gold and photocopies of cheques. As the assessee 3 failed to prove the identity, creditworthiness and genuineness of the transaction by not submitting the relevant documents, the Assessing Officer (“AO”), vide order dated 15/03/2021 passed under section 143(3) read with section ... made by the AO under section 68 of the Act as the assessee failed to prove the identity, 8 creditworthiness and genuineness of the transaction in relation to the introduction of capital by its partners. Thus, it cannot be disputed that the solitary addition made by the AO vide assessment

Parag Pritinath Dunung, Kolhapur vs. ITO, Ward 1(2), Kolhapur

In the result, appeal of the assessee is Partly Allowed

ITA 105/PUN/2025[2017-18]Status: DisposedITAT Pune27 May 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकरअपीलसं. / Ita No.105/Pun/2025 िनधा"रणवष" / Assessment Year: 2017-18 Parag Pritinath Dunung, V The Income Tax Officer, 1529, Cward, Laxmipuri, S. Ward-1(2), Kolhapur. Kolhapur – 416119. Pan: Aaypd2686B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak & Shri Mayuresh Doshi – Ar’S Revenue By Shri Vinod Pawar – Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 27/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated 20.11.2024 For The A.Y.2017-18. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld.Cit (A) Is Not Justified In Confirming The Addition Of Rs 74,91,000/- U/S 68 On Account Of Cash Balance Accumulated Out Of Undisclosed Sources Without Appreciating That The Assessee Has Explained Cash Balance Accumulated From The Regular Business In The Books Of Accounts.

Section 115BSection 143(3)Section 250Section 68

Account. Smt.Yashoda Devi gets Pension from Government. The Assessing Officer has not doubted any of these facts. Therefore, identify of the person, genuineness of the transaction and creditworthiness of the person is established, hence, we direct Assessing Officer to delete the addition of Rs.1,66,389/-. Accordingly, Ground No.3 raised