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“peak credit theory”

Cash Credits & Unexplained ItemsSection 68Section 68215 judgments

The decision most relied on for peak credit theory is Bhaiyalal Shyam Behari v. CIT (276 ITR 38), cited in 63 judgments on BharatTax.

Leading authorities on peak credit theory

Bhaiyalal Shyam Behari v. CIT
276 ITR 38 · 2005 · High Court
63
citing judgments

The peak credit theory applies only to credits and withdrawals that are held to be non-genuine. If the assessee claims all deposits are genuine, the benefit of the peak credit theory may not be available.

552 (SC) Zaveri Diamonds v. CIT 11-12 3
118 Taxmann.com 166 · 2020 · High Court
62
citing judgments

The court considers the evidentiary value of unaudited books and loose papers when assessing income, particularly concerning trade creditors and their verification.

Sh. Rajesh Kumar Jain v. ACIT Hon'ble High Court Of Delhi
84 Taxmann.com 257 · 2017 · High Court
62
citing judgments

The assessment can apply the peak credit theory for additions related to unexplained credits or entries. Furthermore, assessment proceedings are not vitiated merely because the Department proceeded under an incorrect section if material existed to justify the assessment under a proper provision like section 148.

Point E COT v. Vijay Agricultural Industries
294 ITR 610 · 2007 · High Court
37
citing judgments

The peak credit theory is applicable only when the source and corresponding outgo of a deposit are unexplained, and it does not apply to issues concerning purchases.

Navin Shantilal Mehta v. Income-tax Officer, Ward-32 (2) (4), Mumbai
90 Taxmann.com 16 · 2018 · ITAT
35
citing judgments

Addition under section 69C for bogus purchases from non-existent suppliers is justified, even if purchase bills are produced and payments are made through banking channels, if other evidence is lacking.

Commissioner of Income Tax v. D.K. Garg
250 Taxmann 104 · 2017 · High Court
35
citing judgments

An assessee who acts as an accommodation entry provider and cannot explain the sources of deposits and corresponding payments is not entitled to the benefit of peak credit.

III v. Tirupati Construction Co.
55 Taxmann.com 308 · 2015 · High Court
23
citing judgments

The peak credit theory can be applied to determine unexplained income arising from a series of transactions, even when exact quantum is difficult to ascertain. However, it may not be applicable to singular unexplained credits.

Kaveri Rice Mills v. CIT
157 Taxmann 376 · 2006 · High Court
21
citing judgments

The High Court determines whether additions based on uncorroborated purchase invoices are justified when the revenue relies on multiple conflicting precedents.

Judgments citing peak credit theory

Brijesh Kumar Verma, New Delhi vs. DCIT, Central Circle-7, New Delhi

ITA 402/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Feb 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 132(1)Section 139(1)Section 153CSection 69A

Searched without following Section 65B of Indian Evidence Act. The Learned Assessing Officer erred in making addition of Rs. 70,27,262/- following peak credit theory just mechanically, arbitrarily without judicially examining the legal and detailed Submissions of the Appellant. Otherwise also, the calculation of amount of peak credit

Brijesh Kumar Verma, New Delhi vs. DCIT, Central Circle-7, New Delhi

ITA 401/DEL/2023[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 132(1)Section 139(1)Section 153CSection 69A

Searched without following Section 65B of Indian Evidence Act. The Learned Assessing Officer erred in making addition of Rs. 70,27,262/- following peak credit theory just mechanically, arbitrarily without judicially examining the legal and detailed Submissions of the Appellant. Otherwise also, the calculation of amount of peak credit

Incometax Officer, Chennai vs. Chinnan Vaithyalingam, Chennai

In the result, the appeal of the Revenue and stay application of the

ITA 2348/CHNY/2025[2011]Status: DisposedITAT Chennai05 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. T. Vasudevan, AdvocateFor Respondent: Shri. C. Sivakumar, Addl. C.-T
Section 144Section 148

money-lending business. Accordingly, it was argued that the order of the Ld.CIT(A) in restricting the addition by applying the peak credit theory is unsustainable in law and on facts, and therefore liable to be set aside. 10. Per contra, the Ld.AR, drawing our attention to the peak credit ... settled principle that taxing the entire gross deposits would result in multiple additions of the same money. In such circumstances, adoption of the peak credit theory is a reasonable and judicially accepted method to determine the real income embedded in the transactions, particularly when the assessee has not maintained regular

Balan Logeswaran, Namakkal vs. ITO, Ward-1, Tiruchengode

The appeal of the assessee is partly allowed

ITA 2312/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Jan 2026AY 2017-18

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2312/Chny/2025 िनधा"रण वष" /Assessment Year: 2017-18

For Respondent: Ms. R.Kavitha, Addl. CIT
Section 115BSection 145(3)Section 250Section 69A

Rs.2,83,000/- as on 18.06.2016 and Rs.1,13,069/- in the Karur Vysya Bank account as on 31.03.2017, and therefore the peak credit theory should have been applied, restricting the addition to Rs.3,96,069/-. The appellant relied on decisions of the Madras High Court in PCIT ... appeal, the assessee did not dispute the deposits but submitted that only the peak credit in these accounts should be taxed. While the peak credit theory is indeed a judicially recognized method for estimating unexplained income in appropriate cases-particularly where bank accounts reflect repeated deposits and withdrawals suggesting rotation

Naman Khannah, Delhi vs. DCIT, Central Circle-8, Delhi

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

ITA 3332/DEL/2025[2017-18]Status: DisposedITAT Delhi19 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2017-18] Naman Khannah, Dy. Commissioner Of Income Tax, C-5, Pamposh Enclave, Central Circle-8, Greater Kailash-I, Vs New Delhi New Delhi-110048 Pan-Axapk5943R Assessee Revenue Assessee By Shri Vinay Chawla, Adv. Revenue By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 19.01.2026 Date Of Pronouncement 19.01.2026

Section 115BSection 132Section 153C

considered view that the learned AO could not have summarily rejected the assessee’s foregoing explanation before applying the peak credit theory. Accordingly, in the interest of justice, it is deemed appropriate that lumpsum addition of only Rs.2,12,780/- lakhs in the given facts would be just and proper

The DCIT, Central Circle-1, Rajkot vs. Shri Nileshbhai Sureshbhai Untavadiya, Morbi

In the result all the four appeal of Revenue and assessee are allowed for statical purpose

ITA 22/RJT/2024[2021-22]Status: DisposedITAT Rajkot15 Jan 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 22/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT. DR
Section 144Section 250Section 68

customer. The appellant has alternatively stated that if commission income is not accepted then the addition should be based on the peak credit theory. The appellant has relied on the decisions of the Hon'ble ITAT, Rajkot and Ahmedabad in support of his contentions. 13. ITA No. 96/Rjt/2023

Deputy Commissioner of Income Tax Central Circle 1 Rajkot, Rajkot vs. Jaydeep T Badrakia, Morbi

In the result all the four appeal of Revenue and assessee are allowed for statical purpose

ITA 21/RJT/2024[2021-22]Status: DisposedITAT Rajkot15 Jan 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 22/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT. DR
Section 144Section 250Section 68

customer. The appellant has alternatively stated that if commission income is not accepted then the addition should be based on the peak credit theory. The appellant has relied on the decisions of the Hon'ble ITAT, Rajkot and Ahmedabad in support of his contentions. 13. ITA No. 96/Rjt/2023

Jaydeep Thakarshibhai Badrakia, Morbi vs. ACIT, CC-1, Rajkot

In the result all the four appeal of Revenue and assessee are allowed for statical purpose

ITA 453/RJT/2023[2021-22]Status: DisposedITAT Rajkot15 Jan 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 22/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT. DR
Section 144Section 250Section 68

customer. The appellant has alternatively stated that if commission income is not accepted then the addition should be based on the peak credit theory. The appellant has relied on the decisions of the Hon'ble ITAT, Rajkot and Ahmedabad in support of his contentions. 13. ITA No. 96/Rjt/2023

Assistant Commissioner of Income Tax, Central Circle, Patiala vs. Satguru Foundation(Regd), Muktsar

In the result, all the four appeals are dismissed

ITA 494/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh15 Jan 2026AY 2013-14

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

only net profit from the business should be treated as income of the assessee. The assessee has also made arguments for applying peak credit theory in light of debits and credits contained in very same seized documents and argued that if at all document is to be relied upon, then ... only peak credit recorded in the document should be considered as undisclosed income of the assessee. The peak credit theory is not a foreign to the income-tax proceedings. Various courts and tribunals time and again are batting for peak credit theory depending upon facts and circumstances of each case

Asstt. Commissioner of Income Tax, Patiala vs. Satguru Foundation(Regd.), Muktsar

In the result, all the four appeals are dismissed

ITA 493/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh15 Jan 2026AY 2012-13

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

only net profit from the business should be treated as income of the assessee. The assessee has also made arguments for applying peak credit theory in light of debits and credits contained in very same seized documents and argued that if at all document is to be relied upon, then ... only peak credit recorded in the document should be considered as undisclosed income of the assessee. The peak credit theory is not a foreign to the income-tax proceedings. Various courts and tribunals time and again are batting for peak credit theory depending upon facts and circumstances of each case

Assistant Commissioner of Income Tax, Patiala vs. Satguru Foundation(Regd), Muktsar

In the result, all the four appeals are dismissed

ITA 492/CHANDI/2023[2011-12]Status: DisposedITAT Chandigarh15 Jan 2026AY 2011-12

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

only net profit from the business should be treated as income of the assessee. The assessee has also made arguments for applying peak credit theory in light of debits and credits contained in very same seized documents and argued that if at all document is to be relied upon, then ... only peak credit recorded in the document should be considered as undisclosed income of the assessee. The peak credit theory is not a foreign to the income-tax proceedings. Various courts and tribunals time and again are batting for peak credit theory depending upon facts and circumstances of each case

Assisstant Commissioner of Income Tax, Patiala vs. Satguru Foundation(Regd)., Muktsar

In the result, all the four appeals are dismissed

ITA 491/CHANDI/2023[2010-11]Status: DisposedITAT Chandigarh15 Jan 2026AY 2010-11

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 491, 493 & 494/Chd/2023 "नधा"रण वष" / A.Y. : 2010-11, 2012-13 & 2013-14 The Acit, M/S Satguru Foundation (Regd.), Central Circle, Vs Desh Bhagat College & Hospital, Patiala. Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 492/Chd/2023 "नधा"रण वष" / A.Y. : 2011-12 The Acit, M/S Satguru Foundation (Regd.), Patiala. Vs Desh Bhagat College & Hospital, Kotkapura Road, Muktsar. "थायी लेखा सं./Pan No: Aabas1418A अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Abhishekl Pal Garg, CIT DR
Section 147

only net profit from the business should be treated as income of the assessee. The assessee has also made arguments for applying peak credit theory in light of debits and credits contained in very same seized documents and argued that if at all document is to be relied upon, then ... only peak credit recorded in the document should be considered as undisclosed income of the assessee. The peak credit theory is not a foreign to the income-tax proceedings. Various courts and tribunals time and again are batting for peak credit theory depending upon facts and circumstances of each case

Sundaram Subramanian Rep. by Legal Heir S Sundaram, Pudukkottai vs. ITO, Circle-2(1), Trichy

In the result, both the appeals of the Assessee are partly allowed

ITA 2420/CHNY/2025[2014-15]Status: DisposedITAT Chennai12 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 147Section 148Section 251Section 68

bank statement analysis, matching withdrawals or cash flow trial was furnished to prove rotation of the same funds was made to apply the peak credit theory. e) The CIT(A) also did not entertain the ground that the books of accounts has to be rejected u/s.145(3) before concluding ... sustainability of addition u/s.68/69A of the Act, the powers of the Ld.CIT(A) to substitute the charging section, and the applicability of peak credit theory and evidentiary value of books of account. 18. Since facts and grounds are common, both appeals are disposed of by this consolidated order

Sundaram Subramanian, Pudukkottai vs. ITO, Circle-2(1), Trichy

In the result, both the appeals of the Assessee are partly allowed

ITA 2419/CHNY/2025[2013-14]Status: DisposedITAT Chennai12 Jan 2026AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 147Section 148Section 251Section 68

bank statement analysis, matching withdrawals or cash flow trial was furnished to prove rotation of the same funds was made to apply the peak credit theory. e) The CIT(A) also did not entertain the ground that the books of accounts has to be rejected u/s.145(3) before concluding ... sustainability of addition u/s.68/69A of the Act, the powers of the Ld.CIT(A) to substitute the charging section, and the applicability of peak credit theory and evidentiary value of books of account. 18. Since facts and grounds are common, both appeals are disposed of by this consolidated order

Rakesh Divedi, Delhi vs. Income Tax Officer, Ward 43(6), Delhi

In the result, appeal of the Assessee is allowed

ITA 3290/DEL/2025[2009-10]Status: DisposedITAT Delhi09 Jan 2026AY 2009-10

Bench: Shri Sudhir Kumar & Shri Manish Agarwalrakesh Divedi, Income Tax Officer, 87, Triveni Apartments, Ward-43(6), Delhi. Pitampura, New Delhi - Vs. 110034. Pan-Apcpd9179A (Appellant) (Respondent) Shri Pranshu Singhal, Ca Assessee By & Ms. Mansi Jain, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 30/10/2025 Date Of Pronouncement 09/01/2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘Ld. Cit(A)’ In Short) Dated 07.03.2025 In Appeal No.40/10204/2018-19 Arising Out Of The Order Passed By The Income Tax Officer, Ward-40(3) U/S 143(3) Of The Act (‘The Act’ For Short) Dated 20.12.2016 For Assessment Year 2009-10. 2. Brief Facts Of The Case Are That Assessee Is An Individual & Proprietor Of M/S Triambkay Gauri Impex. The Information Was Received By The Ao From Investigation Wing That There Were Cash Deposits In The Bank Account Of The Assesse With Icici Bank, However, Income Of The Assessee & Gross Receipt Has Not Rakesh Divedi Vs. Income Tax Officer Commensurate With The Cash So Deposited, Therefore, After Recording The Reason U/S 147, Notice U/S 148 Was Issued On 31.03.2016 After Obtaining Statutory Approval From The Pcit. Thereafter, Assessment Was Completed Vide Order Dated 20.12.2016 Wherein Total Addition Of Rs. 5,20,88,345/- Was Made U/S 68 Of The Act For Cash Deposited In The Bank Accounts By Holding The Same As Unexplained Cash Credits. 3. Against The Said Order, Assessee Has Filed An Appeal Before Ld. Cit(A) Who Vide Impugned Order Has Partly Allowed The Appeal Of The Assessee & Directed The Ao To Make Addition Of Peak Credit Of The Total Deposits In The Bank Accounts.

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 68

facts and circumstances of the case, the Ld. CIT(A) has erred in directing the AO to make addition on peak credit theory on the cash deposited Rakesh Divedi vs. Income Tax Officer in the bank account amounting to Rs. 5,20,88,345/- and delete the entire cash deposits ... That the Ld. CIT(A) has erred both on facts and in law in directing the AO to adopt the peak credit theory. 6. That the appellant respectfully craves for leave to add, amend, alter, omit or substitute any of the grounds of appeal at any time before

Tej Pal Singh, Reengus vs. Income Tax Officer, Ward Neem Ka Thana, Neem Ka Thana

Appeal of the assessee is allowed for statistical purposes

ITA 877/JPR/2025[2014-15]Status: DisposedITAT Jaipur31 Dec 2025AY 2014-15

Bench: Me That The Capital Gain Earned On This Land Acquired By Nhai Was Exempt In Terms Of Provision Section 10 Sub-Section (37) Of The Act. He Drew My Attention To The Relevant Provision Of Section 10(37) Of The Act As Under:-

For Appellant: Sh. Vedant Gupta, AdvocateFor Respondent: Sh. Gautam Singh Choudhary
Section 10Section 10(37)Section 250

wanted to avoid any litigation and to purchase peace of mind. 17. The ld. CIT(A), he pointed out rejected the peak credit theory, but at the same time confirmed the order of the AO. He drew my attention to para 8.3 of the ld. CIT(A) order as under ... cash flow statement pointing out that no addition was warranted on account of cash deposits in his bank account even after applying the peak credit theory. He further contended that it had been pleaded that there was no admission or agreement by the assessee on the addition to be made

Integrated Service Point Ltd., Chennai vs. ACIT, CC-2(4), Chennai

ITA 1883/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Pvt. Ltd.,) Vs. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement : 13.10.2025 : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

आयकर अपीलीय अधिकरण 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI मप्सनीय श्री मनु कुमार गिरि

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1882/CHNY/2025[2019-20]Status: DisposedITAT Chennai30 Dec 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Andhra Pradesh High Court in CIT v. Purushottam Jhawar [2013] 40 Taxmann.com 533 (Andhra Pradesh), which held as follows: “[Peak credit theory] Block period 1989-90 to 1999-2000 - Whether application of principle of peak credit method in quantifying undisclosed income is one of accepted methods of accounting principles

Integrated Service Point Ltd., Chennai vs. ACIT, Central Circle-2(4), Chennai

ITA 1881/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Dec 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Chennai. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

आयकर अपीलीय अधिकरण 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAΙ मप्सनीय श्री मनु कुमार गिरि

ACIT, Chennai vs. Integrated Service Point Limited, Anna Nagar

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

ITA 1879/CHNY/2025[2022-23]Status: DisposedITAT Chennai30 Dec 2025AY 2022-23

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

For Appellant: Mr. Y. Sridhar, FCAFor Respondent: Mr. Bipin C.N, CIT
Section 132Section 132(4)Section 134(4)Section 250

Andhra Pradesh High Court in CIT v. Purushottam Jhawar [2013] 40 Taxmann.com 533 (Andhra Pradesh), which held as follows: “[Peak credit theory] Block period 1989-90 to 1999-2000 - Whether application of principle of peak credit method in quantifying undisclosed income is one of accepted methods of accounting principles