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“source of source”

Cash Credits & Unexplained ItemsSection 68Section 68810 judgments

The decision most relied on for source of source is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on source of source

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

Totgars Co-operative Sale Society Ltd. v. ITO
322 ITR 283 · 2010 · Supreme Court
1,283
citing judgments

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

K.P. Varghese v. ITO
131 ITR 597 · 1981 · Supreme Court
989
citing judgments

An addition to income cannot be made merely on the basis of a difference in valuation of assets or a Valuation Officer's report without establishing actual understatement of consideration or the source of unexplained funds through proper enquiry. The Assessing Officer must conduct proper enquiry and satisfy the conditions for making such additions.

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT
227 ITR 172 · 1997 · Supreme Court
621
citing judgments

Interest income earned on deposits, particularly before the commencement of business operations or as a requirement for business licensing, is taxable as "income from other sources" under Section 56, and cannot be treated as business income or set off against interest on borrowed funds.

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.

Liberty India v. CIT
317 ITR 218 · 2009 · Supreme Court
571
citing judgments

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

Judgments citing source of source

Income Tax Officer, New Delhi vs. Verve Construction LLP, New Delhi

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

ITA 2536/DEL/2023[2018-19]Status: DisposedITAT Delhi06 Nov 2024AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahmanincome Tax Officer, Vs. Verve Construction Llp, Flat No.502, 502A, 5Th Floor, New Delhi. Narain Manzil – 23, Barakhamba Road, New Delhi – 110 001. (Pan : Aapfv9685D) (Appellant) (Respondent) Assessee By : Shri Ajay Baheti, Ca Revenue By : Ms. Sapna Bhatia, Cit Dr Date Of Hearing : 09.09.2024 Date Of Order : 06.11.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Revenue Against The Order Of Ld. Commissioner Of Income-Tax Appeals /National Faceless Appeal Centre (Nfac) [For Short ‘The Ld. Cit (A)] Dated 12.07.2023 For Assessment Year 2019-19. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income For Ay 2018-19 On 29.08.2018 Declaring Total Income At Rs.Nil. The Return Of Income Was Processed Under Section 143 (1) Of The Income-Tax Act, 1961

For Appellant: Shri Ajay Baheti, CAFor Respondent: Ms. Sapna Bhatia, CIT DR
Section 115BSection 133Section 142(1)Section 143Section 143(2)Section 68

Appellant not only provided all the details as mentioned above but has also discharged its responsibility to provide the details of source of source from where Shipra Estate Limited has raised the funds for making investment in the capital of the Appellant. Papers placed at Pages

Agl Technologies Ltd, New Delhi vs. DCIT Circle-1(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 4692/DEL/2019[2010-11]Status: DisposedITAT Delhi30 Oct 2024AY 2010-11

Bench: Shri Vikas Awasthy & Shri Naveen Chandraआअसं.4692/िद"ी/2019 (िन.व. 2010-11) M/S Agl Technologies Ltd., S-206, First Floor, Panchsheel Park, New Delhi 110017 ...... अपीलाथ"/Appellant Pan: Aaeca-1070-B बनाम Vs. Deputy Commissioner Of Income Tax, Circle-1(1), Room No. 153A, C.R Building, ..... "ितवादी/Respondent I.P Estate0, New Delhi 110002 अपीलाथ" "ारा/ Appellant By : Shri Anuj Jain, Chartered Accountant "ितवादी"ारा/Respondent By : Shri Kanv Bali, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 13/08/2024 घोषणा क" ितिथ/ Date Of Pronouncement : : 30/10/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-1, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 26.03.2019, For Assessment Year 2010-11. 2. The Solitary Ground Raised By The Assessee In Appeal Is Against The Addition Of Rs.1 Crore U/S. 68 Of The Income Tax Act, 1961 (Hereinafter Referred To As 'The Act’).

For Appellant: Shri Anuj Jain, Chartered AccountantFor Respondent: Shri Kanv Bali, Sr. DR
Section 133ASection 139Section 143(1)Section 148Section 68

ought to have been made. In first appellate proceedings, the CIT(A) held that the assessee failed to prove source of source to prove creditworthiness of lender. The ld. Counsel stated that in the impugned AY the assessee was not required to prove source of source ... warranted. 9. Further, a perusal of impugned order shows that the CIT(A) has remarked that the assessee could not prove source of source, hence, creditworthiness of the lender could not be ascertained. The provisions of section 68 of the Act were amended by the Finance

Deputy Commissioner of Income Tax, Central Circel-1(2, Nagpur vs. M/S. Vibrant Global Capital Ltd., Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 229/NAG/2022[2014-15]Status: DisposedITAT Nagpur25 Oct 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore P. DewaniFor Respondent: Shri Sandipkumar Salunke
Section 143(3)Section 14ASection 68

make addition u/s 68 of I.T. Act 1961. I) It is settled position of law that assessee has no obligation to explain source of source. Repayment of loan in the case of four parties during the year under consideration has been accepted by A.O. Repayment of loan ... Thus, in a way, the Hon'ble High court has reiterated the view that the assessee is not required to establish the source of source. The Hon‟ble Jurisdictional High Court in Gaurav Triyugi Singh v/s ITO (supra) has considered this issue in Para

Assistant Commissioner of Income Tax, Cental Circle -2(2), Nagpur vs. Shri Narendra Maganmal Kothari, Nagpur

Accordingly, the grounds raised by the Revenue are dismissed

ITA 330/NAG/2019[2013-14]Status: DisposedITAT Nagpur25 Oct 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Hitesh P. ShahFor Respondent: Shri Sandipkumar Salunke
Section 133(6)Section 68

ranging between Rs. 7.43 lacs to Rs. 86.57 lacs. The assessee has established credit worthiness of the parties by filing details of source of source. The assessee has furnished complete details and said information is genuine (i.e. PAN CARD, ITR, Confirmation, Bank statement) and no efforts was made ... Assessee Company and their year-wise Income Track record proved the capacity of the said Company. The assessee has also proved the Source of source, by bringing on record the source of amount received by the said company along with the nature of transaction

ITO, Ward-6(1)(1), Ahmedabad vs. Parulben Rajubhai Trivedi, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1019/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad23 Oct 2024AY 2013-14

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Biren Shah & Shri Gulab Thakor, A.RsFor Respondent: Shri Biren Shah & Shri Gulab Thakor, A.Rs
Section 263Section 68

cancel the order passed under section 263 of the Act was upheld. Thus, driven by the precedent, where the inquiry of 'source of source' is not found to be the requirement of law, the alleged inadequacy in this respect should not be fastened on the assessee. Notwithstanding ... order. The applicability of the clause is thus essentially contextual. As observed in the preceding paras, even if inquiry with regard to source of source is omitted to be carried out, the provisions of Section 68 of the Act cannot be automatically fastened on the assessee. No objective

Decputy Commission of Income Tax Central Circle-3(1), Kolkata vs. Chirag Jewellers, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1559/KOL/2024[2014-15]Status: DisposedITAT Kolkata21 Oct 2024AY 2014-15

Bench: Shri Rajpal Yadav & Dr. Manish Boradi.T.A. No. 1559/Kol/2024 Assessment Year: 2014-15 Dcit, Central Circle-3(1) Chirag Jewellers 110, Shantipally, Flat 17A, Rameshwara Mansion, 10/4A Vs Kolkata-700107 Elgin Road, Kolkata-700020 West Bengal [Pan : Aabfc7914L] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Subhendu Datta, CIT DR
Section 132Section 143(2)Section 143(3)Section 153ASection 250Section 68Section 69C

furnished replies confirming the transactions entered with the appellant and provided copies of the loan confirmation, IT Return, Audited Accounts, Bank Statement, Source of Source etc. This statement of the appellant in its reply to the showcause has not been rebutted by the AO in his assessment order

Kalindee Estates Private Limited, Jaipur vs. Income Tax Officer, Jaipur

ITA 770/JPR/2024[2010-2011]Status: DisposedITAT Jaipur21 Oct 2024AY 2010-2011
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anup Singh, Addl. CIT
Section 143(3)Section 147Section 68

under consideration is not in accordance with law and deserves to be deleted as the assesse is not required to prove the source of source because such provision was subsequently inserted by Finance Act 2012 w.e.f. 01.04.2013. In this regard reliance is being place on the decision

Samarth Lifestyle Retailing Pvt. Ltd., Jaipur vs. DCIT, Circle-6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 621/JPR/2024[2011-12]Status: DisposedITAT Jaipur17 Oct 2024AY 2011-12
For Appellant: Shri P. C. Parwal, CAFor Respondent: Shri Sanjay Nargas, Addl. CIT
Section 143(1)Section 143(3)Section 147Section 148Section 68

cannot be treated as undisclosed income in the hands of the company. In the present case, the assessee even has proved the source of source, therefore, the creditworthiness was also proved, consequently, no addition made u/s 68 of the Act can be said to be justified. assessee duly ... like PAN, bank account details from the bank, other relevant material, genuineness of the transaction, payment through banking channel and even the source of source, therefore, the assessee has proved the conditions laid down u/s 68 of the Act. It is also noted that in spite of repeated

Asst. Commissioner of Income-Tax, Mumbai vs. Futura Travels Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

ITA 757/MUM/2024[2011-12]Status: DisposedITAT Mumbai16 Oct 2024AY 2011-12
Section 143(3)Section 68

subscribers as long as the onus under Section 68 is discharged by the appellant. Further even the burden to prove the source of source has been introduced with effect from assessment year 2013-14 prospectively by way of proviso to section 68. Hence for the year under consideration

Shivnandan Buildwell Pvt. Ltd., Delhi vs. DCIT, Circle- 23(1), New Delhi

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

ITA 7785/DEL/2018[2013-14]Status: DisposedITAT Delhi16 Oct 2024AY 2013-14

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Section 142Section 142(1)Section 143(2)Section 143(3)

banks to facilitate the transaction. All companies had sufficient funds (refer Chart P.B-1, Page no. 14). Share Applicant wise explanation of source of Source (PB-1, page no. 38-39) alongwith the bank the bank statements of source of source of source. So, the source

DCIT Circle -2(1), Hyderabad vs. Gireesh Infrastructure Pvt Ltd, Hyderabad

In the result, appeal filed by the Revenue is dismissed

ITA 499/HYD/2022[2013-14]Status: HeardITAT Hyderabad15 Oct 2024AY 2013-14

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No. 499/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2013-14) Dy. Cit Vs. Gireesh Infrastructure Circle 2(1) Private Limited Hyderabad Hyderabad Pan: Aadcg3003H (Appellant) (Respondent) राज" व "ारा/Revenue By: Shri Ashish Kumar Shukla, Dr िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca सुनवाई की तारीख/Date Of Hearing: 15/10/2024 घोषणा की तारीख/Pronouncement: 15/10/2024 आदेश/Order

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: Shri Ashish Kumar Shukla, DR
Section 68

Orissa Corporation Pvt Ltd (1986) 159 ITR 78 (S.C). We further note that the appellant has also explained the source of source in respect of loans received from 3 parties and as Page 5 of 7 ITA 499 of 2022 Gireesh Infrastructure P Ltd per the details filed

Deputy Commissioner of Income Tax, Kolkata vs. Sdr Meghnath Investments Private Limited, Kolkata

ITA 1088/KOL/2023[2012-13]Status: DisposedITAT Kolkata15 Oct 2024AY 2012-13

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 131Section 143(3)Section 250Section 253Section 68

investors by filing their audited accounts, income-tax return acknowledgements, certificates of incorporation, bank statements and as well as "source of source" as is evident from case records running into more than 500 pages. All shareholders served notices u/s 131 and further almost all shareholders appeared before ... Page 10 27.10.2011 The appellant during appeal, has furnished the Balance Sheet, Bank Statement and ITR of the source of source, even though, since the amendment to section 68 was introduced from 1.4.2013, it was not applicable for the period relevant for the instant appeal. These were also

Sandesh Projects Pvt. Ltd, Mumbai vs. ITO 11(1)(3), Mumbai

In the result appeal of the assessee is partly allowed

ITA 1734/MUM/2024[2010-11]Status: DisposedITAT Mumbai14 Oct 2024AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

Section 133Section 142Section 143Section 147Section 148Section 68

huge reserve and surplus, these answer could not have been provided by the assessee because assessee is not required to prove the source of source of the cash credit and share capital for Page | 15 ITA No.1734/M/2024 AY: 2010-11 Sandesh Projects Versus Income Tax Officer, Mumbai

Pallav Rajnikant Pancholi, Ahmedabad vs. The ITO, Ward-2, International Taxation, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 489/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad08 Oct 2024AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.489/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Pallav Rajnikant Pancholi The Ito बनाम/ 903, Anurag Flats Ward-2, International Taxation V/S. Nr.Vidhyanagar School Ahmedabad Usmanpura Ahmedabad – 380 014 (Gujarat) "थायी लेखा सं./Pan: Ceepp 9266 D अपीलाथ&/ (Appellant) '( यथ&/ (Respondent) Assessee By : Shri Rajesh C. Shah, Ar Revenue By : Shri Prithviraj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 01/10/2024 घोषणा की तारीख /Date Of Pronouncement: 08/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Rajesh C. Shah, ARFor Respondent: Shri Prithviraj Meena, CIT-DR
Section 143(3)Section 147Section 148ASection 56(2)(x)Section 69A

credited in the NRO account stands fully explained and there is, in fact, no provision u/s 69A of the Act to prove source of source of money found in a bank account. It is, therefore, submitted that the said addition be deleted. It is also submitted that

Ace Cabs Limited, Delhi vs. ACIT, Circle-1(2), Delhi, C R Building

In the result, appeal filed by the assessee is allowed

ITA 443/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Oct 2024AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri S.Rifaur Rahmanace Cabs Limited, Vs. Acit, Circle 1 (2), 562, Silver Oak Lane, Delhi. M.G. Road, Ghitorni, Delhi – 110 030. (Pan : Aaica4494R) (Appellant) (Respondent) Assessee By : Shri Gaurav Jain, Advocate Ms. Bharti Sharma, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 23.07.2024 Date Of Order : 04.10.2024 Order Per S.Rifaur Rahman,Am: 1. This Appeal Has Been Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals), New Delhi [“Ld. Cit(A)”, For Short]/ National Faceless Appeal Centre (Nfac) Dated 12.12.2023 For The Assessment Year 2017-18. 2. The Assessee Submitted An Application Under Rule 29 Of The Itat Rules For Admitting The Additional Evidences & The Contents Thereof Are Reproduced Below:-

For Appellant: Shri Gaurav Jain, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR
Section 142(1)Section 143(2)

identity of the shareholder, genuineness of the transaction and creditworthiness of the shareholder along with the additional requirement of explaining the source of source, as prescribed u/s 68 of the Act. However, in order to strengthen its arguments regarding the onus casted ... genuineness of the transaction along with additional requirement LLP and genuineness of the transaction along with additional requirement of proving “source of source” of proving “source of source” 15.1 Section 68 of the Act deals with cash credits. It casts a Section

Balhanuman Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward-5(4), Kolkata

ITA 116/KOL/2024[2012-13]Status: DisposedITAT Kolkata03 Oct 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2012-13

For Appellant: NoneFor Respondent: Shri Vineet Kumar, Addl. CIT, Sr. DR
Section 131Section 143(2)Section 143(3)Section 14ASection 250Section 68

correct. They are undoubtedly relevant and material facts for ascertaining creditwor- thiness and genuineness of the transactions. 19. The doctrine of "Source of Source" or "Origin of Origin" was explained in the fol- lowing terms:- 24. We are conscious of the doctrine of 'source of source ... each case and strict or stringent test may not be applied to arms length angel investors or normal public issues. Doctrine of 'source of source' or 'origin of origin' cannot be applied universally, without reference to the factual ma- trix and facts of each case. The said test

Amar Pratap Steels Private Limited, Jaipur vs. ITO, Ward-7(2), Jaipur

In the result, appeal of the assessee is partly allowed

ITA 108/JPR/2024[2013-14]Status: DisposedITAT Jaipur03 Oct 2024AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Rohan Sogani, CAFor Respondent: Sh. Monisha Choudhary, Addl. CIT
Section 143(2)Section 143(3)Section 36Section 68

Taxman 141 (Raj) Sec. 68: Identity and genuineness of Cash Creditor proved- No need to prove the capacity of Cash Creditor – source of source not to be enquired. 1.3.v ACIT, Jaipur v M/S Rajasthan Asbestors Cement Co., Jaipur (ITA NO.940/JP/2008) “Now tribunal has upheld the decision

The ACIT, Central Circle-3, Vadodara vs. M/S. Aikya Chemicals Pvt. Ltd., Vadodara

In the result, both the appeals of the Revenue are hereby dismissed

ITA 160/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad01 Oct 2024AY 2015-16

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील (एसएस) सं./I.T (Ss).A. No. 81/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2014-15) बनाम/ Asstt. Commissioner Of M/S. Cube Mines & Income-Tax Minerals Pvt. Ltd. Vs. Central Circle-3, Vadodara 11/C Ground Floor, Jaishri Narayan Co-Operative Hsg. Society, Subhanpura, Gorwa, Vadodara, Gujarat 390015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaccc5761D (Appellant) .. (Respondent) & आयकर अपील (एसएस) सं./I.T (Ss).A. No. 82/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2014-15) & आयकर अपील सं./I.T.A. No. 159/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2015-16) बनाम/ Asstt. Commissioner Of M/S. Iolite Cube Income-Tax Inframaterial Ltd. Vs. Central Circle-3, Vadodara 1, Chandamani Nagar, Vidhya Vihar School Lane, Subhanpura, Vadodara, "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacci5944A (Appellant) .. (Respondent) &

For Appellant: Shri Jigar Adhiyaru, A.RFor Respondent: Shri H. Phani Raju, CIT. DR
Section 132Section 153A

erred in holding that the assessee has not only furnished the source of credit entries but also explained the source of source. (3) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred deleting the addition, ignoring

The ACIT, Central Circle-3, Vadodara vs. M/S. Iolite Cube Inframaterial Ltd., Vadodara

In the result, both the appeals of the Revenue are hereby dismissed

ITA 159/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad01 Oct 2024AY 2015-16

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील (एसएस) सं./I.T (Ss).A. No. 81/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2014-15) बनाम/ Asstt. Commissioner Of M/S. Cube Mines & Income-Tax Minerals Pvt. Ltd. Vs. Central Circle-3, Vadodara 11/C Ground Floor, Jaishri Narayan Co-Operative Hsg. Society, Subhanpura, Gorwa, Vadodara, Gujarat 390015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaccc5761D (Appellant) .. (Respondent) & आयकर अपील (एसएस) सं./I.T (Ss).A. No. 82/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2014-15) & आयकर अपील सं./I.T.A. No. 159/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2015-16) बनाम/ Asstt. Commissioner Of M/S. Iolite Cube Income-Tax Inframaterial Ltd. Vs. Central Circle-3, Vadodara 1, Chandamani Nagar, Vidhya Vihar School Lane, Subhanpura, Vadodara, "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacci5944A (Appellant) .. (Respondent) &

For Appellant: Shri Jigar Adhiyaru, A.RFor Respondent: Shri H. Phani Raju, CIT. DR
Section 132Section 153A

erred in holding that the assessee has not only furnished the source of credit entries but also explained the source of source. (3) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred deleting the addition, ignoring

M/S Metal Impex, Chennai vs. ACIT, Central Circle-1(1), Chennai

In the result, all the appeals in ITA Nos

ITA 805/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Sept 2024AY 2020-21

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri V. Nandakumar, CIT
Section 132Section 143(1)Section 143(2)Section 143(3)Section 153ASection 153CSection 153C(2)Section 68

cash credit represented by share application monies of Rs.5,38,35,000/- u/s 68 of the Act. According to the AO, the source of source of the monies received from shareholder, M/s Hari Trafin Pvt Ltd was not properly explained, and therefore the same was added as unexplained