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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

M/S. South West Pinnacle Exploration Limited, Gurugram vs. ACIT, Circle-24(1), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 4076/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarm/S. South West Pinnacle Exploration Limited, Vs. Acit, Circle 24 (1), Plot No.6, 4Th Floor, Sector 44, New Delhi. Gurugram – 122 003 (Haryana). (Pan : Aakcs3608R) (Appellant) (Respondent) Assessee By : Shri I.P. Bansal, Advocate Shri Vivek Bansal, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 25.11.2026 Date Of Order : 21.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-24, New Delhi [“Ld. Cit (A)”, For Short] Dated 17.06.2025 For The Assessment Year 2014-15. 2. At The Outset, Ld. Ar Of The Assessee Submitted That The Issues Involved In The Present Appeal Are Squarely Covered By Various Decisions & He Heavily Relied Upon The Decision Of The Coordinate Bench In The Case Of Real Innerspring Technologies Pvt. Ltd. Vs. Acit (2025) 174

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR
Section 131(1)(d)Section 142(1)Section 143(2)

producing all these evidences the assessee has discharged its primary 13 onus and assessee is under no legal obligation to prove the source of source. 19. He further submitted that it is also pertinent to note that the interest bearing loans were obtained by the assessee according

Amplex Projects Private Limited, Agartala vs. DCIT/ACIT, Circle Silchar, Silchar

In the result, appeal of the assessee is allowed in above terms

ITA 333/GTY/2025[2013-14]Status: DisposedITAT Guwahati19 Jan 2026AY 2013-14

Bench: the Ld. CIT(A).

For Respondent: Shri Santosh Kumar Karnani, Addl. CIT
Section 1Section 139(1)Section 143(3)Section 153ASection 245DSection 245D(4)Section 250

power and wherewithal to trace any person. Moreover, it is settled law that the assessee need not to prove the "source of source"." As such, taking into consideration the above judicial pronouncements, it clearly follows that the alleged share applicant companies by filing the aforementioned documents has duly

Assistant Commissioner of Income Tax, New Delhi vs. Jalco Financial Services Private Limited, New Delhi

The appeal is dismissed

ITA 4209/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveenc Chandraacit, Vs. Jalco Financial Services Room No. 316A, C.R. Private Limited Building, I.P. Estate, K-7B, Ground Floor, New Delhi – 110002 Kalkaji, New Delhi – 110019 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacj2791E Appellant .. Respondent

For Appellant: Sh. MayankPatawari, AdvFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(1)Section 143(3)Section 15HSection 37Section 37(1)Section 68

failed to establish any nexus by bringing any material evidence between FCPL and Sh. Vikas Kumar Aggarwal. (viii) The onus to prove source of source under section 68 of the Act in cases involving credits other than share application money is not perceived under law during the year

Kameshwar Alloys and Steels Pvt. Ltd., Kolkata vs. ACIT, Central Circle-1, Ranchi

In the result, the appeal of the assessee is allowed

ITA 49/RAN/2024[2014-15]Status: DisposedITAT Ranchi14 Jan 2026AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

Section 131Section 132(1)Section 133(6)Section 133ASection 143(3)Section 144Section 153ASection 250Section 68

paper- book. We further note that the investor companies have good earnings and net worth and even the source of source was proved by the investing companies and the authorities below have not done any verification or conducted any enquiry into the evidences/documents filed by the assessee

Rajiv Goyal, Patiala, Punjab vs. Jao ITO Ward-3, Patiala

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

ITA 481/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh14 Jan 2026AY 2018-19

Bench: the CIT(A) have not been considered properly.

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR (Virtual Mode)
Section 115BSection 68Section 69

from pages 9 to 14 of the order were made and again reiterated that the assessee has even proved the source of source of the said lenders, who had advanced the amount to assessee. Thus, there was no justification with the Assessing Officer to make the addition ... confirmation of the lenders alongwith PAN Number, Bank Statement of the lenders, from where, the amount had been advanced and even the 'source of source' of the lenders have been explained so there was no justification for the addition. 4.1 The CIT(A), however, confirmed the order

ACIT, Central Circle, Ghaziabad vs. Al-Arsh Exports Pvt. Ltd, New Delhi

In the result, the appeal of the Revenue in ITA No

ITA 227/DEL/2024[2014-15]Status: DisposedITAT Delhi14 Jan 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla[Assessment Year:2014-15] Acit, Central Circle, Al-Arsh Exports Pvt Ltd., Room No.229, 2Nd Floor, 30, Bazar Lane, Cgo Complex-1, Vs C.P. Bengali Market, Hapur Chungi Ghaziabad, New Delhi-110001 Uttar Pradesh-201002 Pan Aalca5543N Appellant Respondent Cross Objection No.14/Del/2024 [In Ita No.227/Del/2024] [Assessment Year:2014-15] Al-Arsh Exports Pvt Ltd., Acit, Central Circle, Room No.229, 2Nd Floor, 30, Bazar Lane, C.P. Bengali Market, Vs Cgo Complex-1, New Delhi-110001 Hapur Chungi Ghaziabad, Uttar Pradesh-201002 Pan Aalca5543N Appellant Respondent Revenue By Shri Mukesh Kumar Jha, Cit(Dr) Assessee By Shri Swaran Singh, Ca & Shri Vipan Kundra, Ca Date Of Hearing 15.12.2025 Date Of Pronouncement 14.01.2026

Section 120(4)(b)Section 139(1)Section 143(3)Section 147Section 148Section 2Section 68

response to notices u/s 133(6) filed detailed submissions during the assessment proceedings including their ITRs, confirmations, bank account statements and the source of source. 5. No statement of the Directors/Employees of the investor companies is there to support the view of the AO. 6. Once the assessee ... filed detailed evidences regarding the identity, credibility, genuineness and source of source of the investors, the onus shifted on the AO to rebut the evidence. 7. The three basic requirements of Section 68 were fulfilled by the appellant during the assessment proceedings. 8. There are enough legal precedents

Exotica Enclave Pvt. Ltd., Kolkata vs. I.T.O., Ward - 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2003/KOL/2025[2012-2013]Status: DisposedITAT Kolkata12 Jan 2026AY 2012-2013

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 131Section 142(1)Section 143(2)Section 250Section 68

examined the source of funds of each of the four (4) shareholders and found that only the source of source of funds of one (1) shareholder, Mr. Brahmanand Goel was verifiable and that the source of source of funds of other three (3) shareholders ... issued u/s. 131 of the Act was complied with as well. According to him, the assessee was not required to substantiate the source of source of funds, as the proviso to Section 68 of the Act was applicable only from AY 2013- 14. He further took us through

Rk Interiors Cfs (India) Private Limited, Hyderabad vs. ITO, Ward - 3(1), Hyderabad

In the result, appeal of the Assessee is allowed

ITA 1865/HYD/2025[2023-24]Status: DisposedITAT Hyderabad09 Jan 2026AY 2023-24

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1865/Hyd/2025 Assessment Year 2023-2024 M/S. Rk Interiors Cfs (India) Private Limited, The Income Tax Officer, Vs. Hyderabad – 500 034. Ward-3(1), Telangana. Hyderabad. Pan Aakcr1592H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca M V Prasad राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 17.12.2025 घोषणा की तारीख/Pronouncement: 09.01.2026 आदेश/Order

For Appellant: CA M V PrasadFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(1)Section 194QSection 40Section 68

transactions cannot be doubted. The learned Authorised Representative of the Assessee has further submitted that the assessee has proved the source of source by giving all the relevant details and evidence of the partnership firm having sufficient funds and withdrawal by the partners. He has thus contended that ... sec.68 of the Act, the assessee has fully discharged its onus to prove the identity and creditworthiness of the creditors including the source of source as well as genuineness of the transaction. The Assessing Officer has failed to bring any material to disprove the claim of the assessee

Baba Healthcare Private Limited vs. ACIT Circle -1, Fbd

In the result, the appeal of the Assessee is allowed for statistical

ITA 476/DEL/2025[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshbaba Healthcare Pvt. Ltd, Vs. Acit, C/O. Ipso Legal, H-35, 1St Circle-1, Floor, Jangpura Faridabad Extension, New Delhi (Appellant) (Respondent) Pan: Aadcb7985R Assessee By : Shri Rajiv Saxena, Adv Ms. Ssumnagla Saxena, Adv Shri Dishant Sethi, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 04/12/2025 Date Of Pronouncement 07/01/2026

For Appellant: Shri Rajiv Saxena, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 133(6)Section 143(3)Section 56(2)(vii)Section 68

recovered during the year and those amounts were duly invested in the Assessee Company towards share capital and share premium. Hence the source of source is also established beyond reasonable doubt. In our considered opinion, these facts require factual verification by the Learned AO. Hence in the interest

Passion Realtech Private Limited, Gurgaon vs. ACIT, Central Circle-2, Faridabad

In the result appeal of the assessee is partly allowed

ITA 1248/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 131Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 250Section 68

support the source of loan received. No legal obligation is prescribed upon the assessee in law to prove the creditworthiness of ‘source of source’ of receipts obtained by the assessee in view of firstly, the prospective insertion to proviso to section 68 of the Act from

M/S Anjeneye Ispat Ltd., Saraikela vs. Deputy Commissioner of Income Tax, Circle-1, Jamshedpur

In the result the appeal of the assessee is allowed

ITA 74/RAN/2022[2008-09]Status: DisposedITAT Ranchi06 Jan 2026AY 2008-09

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.74/Ran/2022 Assessment Year: 2008-09 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand – 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur……....….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 11, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Ld. Cit(A)”) Dated 21.08.2018 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company Is Engaged In The Manufacturing Of Pig Iron. It Filed Its Return Of Income Declaring Total Income Of ₹1,41,05,250, Which Was Processed Under Section 143(1). During The Assessment Proceedings, The Assessing Officer Noticed That The Assessee Had Received Share Capital & Share Premium Aggregating To ₹3,00,00,000 During The Relevant Previous Year. The Assessing Officer Issued Notices Under Sections 142(1) & 148 Requiring The Assessee To Furnish Complete Details Of The Share Applicants, Including Identity, Creditworthiness & Genuineness Of The Transactions. In Response, The Assessee Furnished Complete Details In Respect Of The Share Capital/Share Premium Received From The Following Parties:

Section 133(6)Section 143(1)Section 154Section 250Section 68

investments. 4.1 The ld. AR also brought to our notice that the amendment to section 68 of the Act relating to “source of source” introduced by the Finance Act, 2012 is prospective and applicable only from AY 2013–14 onwards. Accordingly, for the year under consideration, the assessee ... those cheques.” I.T.A. No.74/Ran/2022 M/s Anjeneya Ispat Ltd 5.3 We note that amendment to section 68 of the Act relating to “source of source” introduced by the Finance Act, 2012 is prospective and applicable only from AY 2013–14 onwards and in this case, for the year under

Goldmoon Exports Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(2), Kolkata

The appeal of the assessee is allowed

ITA 2086/KOL/2025[2012-2013]Status: DisposedITAT Kolkata05 Jan 2026AY 2012-2013

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 131Section 143(1)Section 143(2)Section 250Section 68

said amendment is not applicable to the year under consideration. The assessee is required to prove the source and not the source of source. The case the assessee is squarely covered by the decision of the Hon’ble Bombay High Court in the case

Deputy Commissioner of Income Tax (Central Circle)-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1563/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

creditors and genuineness of the transactions were duly proved. He, further submitted that the assessee was not supposed to prove the source of source. He has further submitted that all the loans have been repaid and the repayment has been accepted by the Revenue. He relied upon

Deputy Commissioner of Income Tax, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1562/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

creditors and genuineness of the transactions were duly proved. He, further submitted that the assessee was not supposed to prove the source of source. He has further submitted that all the loans have been repaid and the repayment has been accepted by the Revenue. He relied upon

DCIT, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1451/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

creditors and genuineness of the transactions were duly proved. He, further submitted that the assessee was not supposed to prove the source of source. He has further submitted that all the loans have been repaid and the repayment has been accepted by the Revenue. He relied upon

DCIT, Central Circle-1(4), Ahmedabad vs. Hindva Builders, Ahmedabad

In the result, all the four appeals of the Revenue are hereby dismissed

ITA 1450/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Sl.Nos.1 & 2 - Shri R.P. Rastogi, CIT-DR
Section 147Section 148Section 148ASection 149Section 250Section 3(1)

creditors and genuineness of the transactions were duly proved. He, further submitted that the assessee was not supposed to prove the source of source. He has further submitted that all the loans have been repaid and the repayment has been accepted by the Revenue. He relied upon

ACIT, Circle - 34(1), Delhi, Civic Centre, New Delhi vs. Gurkirat Bpo Services LLP, Delhi

In the result, the appeal of the Revenue Department is dismissed

ITA 697/DEL/2025[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2017-18 Acit, Vs. Gurkirat Bpo Services Llp, Circle 34(1), G-21, Flat No.256-257, Delhi. Sector-7, Rohini, New Delhi – 110 009. Pan: Aaqfg4414J (Appellant) (Respondent) Assessee By : Shri Y.K. Sud, Ca Revenue By : Shri Dayainder Singh Sidhur, Cit-Dr Date Of Hearing : 27.10.2025 Date Of Pronouncement : 31.12.2025 Order Per Vimal Kumar, Jm:

For Appellant: Shri Y.K. Sud, CAFor Respondent: Shri Dayainder Singh Sidhur, CIT-DR
Section 142(1)Section 143(1)Section 143(3)Section 250Section 68

report of the AO on additional evidence during the appellate proceedings. 5. The ld. AR for the respondent assessee submitted that the source of source was explained in the appellate proceedings. 6. From examination of the record, in the light of the aforesaid rival contentions, the ld.CIT

New Track Exim Private Limited, Delhi vs. Income Tax Officer, Ward 18(3), Delhi

In the result, appeal of the assessee is partly allowed

ITA 2765/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: SHRI SUDHIR KUMAR (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 143(1)Section 143(3)Section 147Section 148Section 151Section 250Section 68

there were sufficient funds available in its bank account, as and when funds were transferred to the assessee company and thus, the source of source is also proved, though, it was not required to establish since the law stood amended vide Finance Act, 2022 w.e.f. 01.04.2023 and applicable ... thus this amendment is not applicable however, as observed above, the assessee has discharged the burden of establishing the source of source by filing the bank statement of the loan creditor. 19. It is also a matter of fact that the entire loan taken was repaid much before

M/S Akshaj Infra Private Limited, Delhi vs. DCIT, Chandigarh

In the result, appeal of the Assessee is dismissed

ITA 725/CHANDI/2015[2009-10]Status: DisposedITAT Chandigarh30 Dec 2025AY 2009-10

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manav Bansal, CIT, DR
Section 132Section 153A(1)(b)Section 68

entries in his bank statement stood fully and completely explained, and that there existed no onus on the Appellant to explain the source of source. (ii) Rs. 40,00,000.00 received from Amarnath Industries in respect whereof the Appellant had filed the confirmation, bank statement and acknowledgement

Westcourt Hospitality Pvt Ltd, New Delhi vs. DCIT, Circle-25(1), Delhi

In the result appeal of the assessee is allowed

ITA 3351/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year: 2018-19] Acit, Circle 25(1), Room Vs M/S. Westcourt Hospitality No. 192A, Cr Building, Pvt. Ltd. Ip Estate New-Delhi. 4391, B-5 & 6, Vasant Kunj, 110002 New Delhi-110070. Pan-Aaacw8734G Appellant Respondent [Assessment Year: 2018-19] M/S. Westcourt Hospitality Vs Acit, Circle 25(1),Room Pvt. Ltd. No. 192A, Cr Building, Ip 4391, B-5 & 6, Vasant Estate New-Delhi. 110002 Kunj, New Delhi-110070. Pan-Aaacw8734G Appellant Respondent

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68

ingredients required u/s 68 of the Act as the CCD allotted are in the nature of borrowing. Ld. AR submits that the source of source was also established by filing the copy of agreement through which the family member of the director Shri Manoharan Govindaswamy received the funds ... given as refundable security, it was wrongly presumed by the At that they have no creditworthiness. Ld. AR submits that once the source of source is established, the ld. CIT(A) has rightly deleted the addition, and he prayed for the confirmation of the said order on this