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“trade creditors”

Cash Credits & Unexplained ItemsSection 68Section 68238 judgments

The decision most relied on for trade creditors is Orient Trading Co. Ltd. v. CIT (49 ITR 723), cited in 123 judgments on BharatTax.

Leading authorities on trade creditors

Orient Trading Co. Ltd. v. CIT
49 ITR 723 · 1963 · High Court
123
citing judgments

When a cash credit is found, the assessee discharges the initial burden by proving the identity of the creditor and the genuineness of the transaction, shifting the burden to the Revenue. The assessee is not required to prove the source of the creditor's funds (source of source).

CIT v. Korlay Trading Co. Ltd.
232 ITR 820 · 1998 · High Court
122
citing judgments

To discharge the onus under Section 68, an assessee must establish the identity of the creditor, the genuineness of the transaction, and the creditworthiness of the creditor. Merely providing basic documentary evidence or a file number is insufficient; each credit entry requires a separate, detailed explanation.

CIT v. Gotan Lime Khaniz Udyog
256 ITR 243 · 2002 · High Court
89
citing judgments

The mere rejection of an assessee's books of account under Section 145(3) does not automatically warrant an addition to the returned income. The Assessing Officer must consider the books alongside historical data and other collected material after confronting the taxpayer.

CIT v. Shri Vardhman Overseas Ltd.
343 ITR 408 · 2012 · High Court
76
citing judgments

An addition under Section 68 cannot be made for genuine sundry creditors or trade payables merely carried forward from previous assessment years if there is no fresh credit in the relevant assessment year. Section 41(1) does not apply to acknowledged outstanding liabilities without actual remission or cessation.

Aravali Trading Co. v. ITO
8 DTR 199 · 2008 · High Court
71
citing judgments

An assessee discharges their onus under Section 68 for cash credits by proving the identity of the creditor, the genuineness of the transaction, and the creditor's creditworthiness. The assessee is not required to prove the source of the creditor's funds ('source of source'), unless evidence suggests the money originated from the assessee itself.

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.

Chief CIT v. Kesaria Tea Company Limited
254 ITR 434 · 2002 · Supreme Court
59
citing judgments

For Section 41(1) of the Income Tax Act to apply, the mere expiry of the limitation period does not constitute cessation of liability; there must be an explicit act by the creditor, such as a release or admission of write-off, confirming that the liability has ceased without the possibility of revival.

Hindustan Tea Trading Co. Ltd. v. CIT
263 ITR 289 · 2003 · High Court
55
citing judgments

Under Section 68, the assessee discharges the initial onus by producing sufficient material and explanation for cash credits. Once material is provided, the Assessing Officer must conduct a proper and thorough inquiry into it, as a half-hearted inquiry or overlooking materials is impermissible.

Judgments citing trade creditors

Samar Exports, Madurai vs. ITO, Ncw-1(7), Madurai

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

ITA 2355/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Mar 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. T.Mythili, JCIT
Section 143(3)Section 68

current account has been credited and the corresponding cash deposits have been debited and it has been utilized for settling of dues of trade creditors outstanding payable Rs.77,03,947/-. 6. No addition can be made once the tax payer has properly explained the source. 7. The Id. AO made

Patel Wines, Kheda vs. The Dy.CIT, Kheda Circle, Nadiad

In the result, the appeal of the assessee is dismissed

ITA 1740/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Divatia, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 133ASection 250

repayments were also made for years with respect to loan taken by the assessee. The Assessing Officer also noted that certain trade creditors had remained outstanding for many years and were subsequently written off and offered to tax in later assessment years, which, according to the Assessing Officer, indicated that

Assistant Commissioner of Income Tax, Mumbai vs. Freightbridge Logistics Private Limited, Mumbai

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

ITA 7792/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Feb 2026AY 2022-23

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Ajay R. Singh a/w Mr. Akshay PawarFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 133(6)Section 143(3)Section 250Section 44B

supporting evidences submitted during assessment proceedings. 3. Confirmations from 26 vendors amounting to 18.18 crores were furnished, representing more than 70% of total trade creditors as on 31.03.2022. 4. Party-wise ledger accounts, expense details, and bank statements were submitted to establish the genuineness of transactions and payments made during ... related to this issue stand allowed.” 5. The Ld. DR contended that the assessee had failed to substantiate the genuineness and creditworthiness of the trade creditors. It was submitted that the explanation furnished by the assessee before the Ld. AO was neither adequate nor supported by cogent documentary evidence

ACIT, Circle-7(1), Delhi vs. Eberspaecher Suetrak Bus Climate Control Systems India Private Limited, Delhi

Appeal is dismissed as premature

ITA 3665/DEL/2025[2014-15]Status: DisposedITAT Delhi12 Feb 2026AY 2014-15

Bench: Shri.Rifaur Rahman & Shri Vimal Kumar

Section 133(6)Section 142(1)Section 143(2)Section 144Section 68

record, the Assessing Officer completed the assessment by making substantial additions under section 68 of the Act in respect of share capital and trade creditors. The Assessing Officer further disallowed current liabilities, various expenses, depreciation and warranty provisions. 3. Aggrieved by the assessment order, the assessee preferred an appeal before ... assessing officer has observed that: “4.1 On examining the ITR of the assessee for AY 2014-15, it was observed that the assessee has trade creditors the tune of Rs. 9,27,25,405/- from different person/entities Vide notice dated 15.11.20.16 the assessee was asked to produce proper details

Goutam Chand Sandeep Pagariya, Chennai vs. ITO, Ncw-8(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 2927/CHNY/2025[2018-19]Status: DisposedITAT Chennai10 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2927/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr.K.P. Gangi Reddi, C.A ()For Respondent: Ms. R. Anitha, Addl. CIT
Section 133(6)Section 194CSection 250Section 40Section 68Section 69C

which it is clear that the unsecured loans as considered by the A.O includes a sum of Rs.1,37,71,710/-outstanding to trade creditor M/s. Prakash Gold Palace. The Ld. AR further submitted that the A.O has considered the trade creditor as unsecured loan and treated the same ... unsecured loans as addition us/. 68 of the Act, we notice that the assessee has submitted the below reconciliation explaining the fact that the trade creditor has been considered as unsecured Goutam Chand Sandeep Pagariya :- 6 -: loans by the A.O and in reality there has been a decrease

Max Media Technologies Private Limited, Mumbai vs. ITO Ward 12(3)(1), Mumbai

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

ITA 4922/MUM/2025[2013-14]Status: DisposedITAT Mumbai10 Feb 2026AY 2013-14

Bench: Smt. Beena Pillai ()

Section 142(1)Section 143(2)Section 41(1)Section 419

Hainan Peng Hua National Industries, both being Hong Kong-based entities, and that the outstanding balances were continuing to be reflected as trade creditors since FY 2008–09 & 2009-10 respectively. The assessee submitted before the Ld. AO that, the amounts represented outstanding liabilities and did not amount to cessation

Priya Enterprise, Vapi vs. ITO, Ward-7, Vapi

In the result, the appeal of the assessee is allowed

ITA 800/SRT/2025[2010-11]Status: HeardITAT Surat23 Jan 2026AY 2010-11

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Raghunath Kamble

For Appellant: Shri Rajesh Upadhyay, ARFor Respondent: Ms Namita Patel, Sr. DR
Section 250

rejection of books of account or bringing any adverse evidence to disprove the identity or genuineness of the creditors. Once purchases are accepted, corresponding trade creditors cannot be treated as unexplained. Accordingly, the additions confirmed by the Ld. CIT(A) is deleted. 9. In the result, the appeal

Assistant Commissioner of Income Tax, Tirunelveli vs. Ponkumari Wind Farm, Kanyakumari

In the result, the appeals filed by the Revenue the cross objections filed by the assessee are dismissed

ITA 2567/CHNY/2025[2006-07]Status: DisposedITAT Chennai21 Jan 2026AY 2006-07

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita Nos.: 2566 & 2567/Chny/2025 िनधा"रण वष"/Assessment Years:2005-06 & 2006-07 & C.O. No.87 & 88/Chny/2025 [In I.T.A.Nos.2566 & 2567/Chny/2025] The Assistant Commissioner Of M/S. Ponkumari Wind Farm, Income Tax, Vs. No.17/41D, Chunkankadai Circle-1, Aloor Road, Nagercoil, Tirunelveli Kanyakumari – 629 807. Pan: Aaffp 1746B (अपीलाथ"/Appellant) (""यथ"/Respondent)/Cross Objector राज"व क" ओर से /Revenue By : Shri Shiva Srinivas, Cit िनधा"रती क" ओर से/Assessee By : Shri T. Vasudevan, Advocate सुनवाई क" तारीख/Date Of Hearing : 14.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 21.01.2026

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 132Section 148Section 153CSection 250Section 41(1)

bogus. It was also observed that no defects in the books of account of the appellant were found. The Hon’ble ITAT found the trade creditors were genuine and the relevant part of the decision was reproduced above. 5.7.2 It was also noted by CIT(A) and ITAT that ... appellant had written off the trade creditors of Rs.10.41 crores to profit and loss account for AY 2010- 11 and had paid taxes on the same. 5.7.3 In view of the CIT(A) and ITAT holding that the trade creditors being genuine

Assistant Commissioner of Income Tax, Tirunelveli vs. Ponkumari Wind Farm, Kanyakumari

In the result, the appeals filed by the Revenue the cross objections filed by the assessee are dismissed

ITA 2566/CHNY/2025[2005-06]Status: DisposedITAT Chennai21 Jan 2026AY 2005-06

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita Nos.: 2566 & 2567/Chny/2025 िनधा"रण वष"/Assessment Years:2005-06 & 2006-07 & C.O. No.87 & 88/Chny/2025 [In I.T.A.Nos.2566 & 2567/Chny/2025] The Assistant Commissioner Of M/S. Ponkumari Wind Farm, Income Tax, Vs. No.17/41D, Chunkankadai Circle-1, Aloor Road, Nagercoil, Tirunelveli Kanyakumari – 629 807. Pan: Aaffp 1746B (अपीलाथ"/Appellant) (""यथ"/Respondent)/Cross Objector राज"व क" ओर से /Revenue By : Shri Shiva Srinivas, Cit िनधा"रती क" ओर से/Assessee By : Shri T. Vasudevan, Advocate सुनवाई क" तारीख/Date Of Hearing : 14.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 21.01.2026

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 132Section 148Section 153CSection 250Section 41(1)

bogus. It was also observed that no defects in the books of account of the appellant were found. The Hon’ble ITAT found the trade creditors were genuine and the relevant part of the decision was reproduced above. 5.7.2 It was also noted by CIT(A) and ITAT that ... appellant had written off the trade creditors of Rs.10.41 crores to profit and loss account for AY 2010- 11 and had paid taxes on the same. 5.7.3 In view of the CIT(A) and ITAT holding that the trade creditors being genuine

Lal Babu Prasad, Siwan vs. ACIT, Circle-2, Muzaffarpur

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

ITA 317/PAT/2025[2015-16]Status: DisposedITAT Patna16 Jan 2026AY 2015-16

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 133ASection 250Section 43B

amounting to ₹29,80,060 were shown as payable at the end of the year. From the ledger accounts creditors, it was noticed that trade creditors amounting to ₹5,06,766 were outstanding. Since the assessee failed to verify ₹24,73,594 was treated as unexplained cash credit and added ... assessee is in appeal before the Tribunal. 8. The learned AR submitted that the assessment involved multiple factual issues relating to stock discrepancy, trade creditors, unrecorded purchases and statutory disallowances. It was contended that the assessee did not get adequate opportunity to present his case before

Smt. Kusum Kujwal, Nainital vs. PCIT, Baireilly

Appeal is dismissed in above terms

ITA 102/DDN/2025[2020-21]Status: DisposedITAT Dehradun13 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: NoneFor Respondent: Ms. Poonam Sharma, CIT-DR
Section 2(14)(iii)Section 263Section 45(2)Section 50C

Allahabad) held that, ”Return filed by assessee was scrutinized and assessment was completed. Thereafter, Commissioner noticed that AO had not conducted proper entries and trade creditors- He exercised his jurisdiction u/s 263 and remanded matter to AO-Assessee filed writ petition against the order. Records showed that ... verify genuineness of trade creditors and assessment order was completely 5 Kusum Kujwal silent and bereft of any discussion on material points- Whether, therefore, assessment order was erroneous and prejudicial to interest or Revenue.” Held, yes. It was further held by the Hon’ble Court that: “The Commissioner may consider

Dalavai Audikesavulu Srinivas L/H of Late Smt D A Sathyaprabha, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 1050/BANG/2025[2017-18]Status: DisposedITAT Bangalore12 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 234ASection 271(1)(c)Section 69B

appreciated that credit balance of Rs.35,00,000/- could not be added as cessation of liability: (i) Because, the credit balance is not a trade creditor, but loan on capital account and therefore, outside the scope of section 41(1) of the Act. (ii) Because, the credit balance ... income in Profit 86 loss account, in contra-distinction to the cases relied upon by the learned AO. (iii) Because, the credit balances, whether trade creditors or capital account balances, cannot be subjected to tax u/s 41(1) or 28(iv) merely on the ground that the same is barred

Dalavai Audikesavulu Srinivas L/H of Late Smt D A Sathyaprabha, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 1049/BANG/2025[2013-14]Status: DisposedITAT Bangalore12 Jan 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri H. Siva Prasad Reddy, ITPFor Respondent: Shri Shivanand H Kalakeri, CIT-DR
Section 132(4)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 234ASection 271(1)(c)Section 69B

appreciated that credit balance of Rs.35,00,000/- could not be added as cessation of liability: (i) Because, the credit balance is not a trade creditor, but loan on capital account and therefore, outside the scope of section 41(1) of the Act. (ii) Because, the credit balance ... income in Profit 86 loss account, in contra-distinction to the cases relied upon by the learned AO. (iii) Because, the credit balances, whether trade creditors or capital account balances, cannot be subjected to tax u/s 41(1) or 28(iv) merely on the ground that the same is barred

ACIT-1(1), Indore vs. Kriti Nutrients Limited, Indore

The appeal of the Revenue is allowed for statistical

ITA 780/IND/2024[2021-22]Status: DisposedITAT Indore09 Jan 2026AY 2021-22

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 246ASection 250Section 253

IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M

Dy. Commissioner of Income Tax, Jaipur, Rajasthan, India vs. Manav Pansari, Rajasthan, India

17. In view of the above discussion, we do not find any merit in the appeal filed by the department

ITA 1188/JPR/2025[2013-14]Status: DisposedITAT Jaipur22 Dec 2025AY 2013-14

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपीलसं. / ITA No. 1188/JPR/2025 निर्धारण वर्ष / AssessmentYear : 2013-14 Dy. Commissioner of Income Tax, Jaipur. बनाम Manav Pansari Vs. A-7, Showromm Sethi colony, TA Main Agra Road, Jaipur. अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No. AARPP1288Q निर्धारिती की ओरसे / Assessee by : Shri Vishnu Khandelwal, CA. राजस्व की ओरसे / Revenue by: Mrs. Alka Gautam, CIT. सुनवाई की तारीख / Date

For Appellant: Shri Vishnu Khandelwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 147Section 148Section 148ASection 69A

towards 7 Manva Pansari, Jaipur. telephone and mobile expenss, Rs. 8322/- towards power and electricity expenses. We are enclosing herewith copies of account of Trade creditors in the books of M/s Pansari gems International showing the payment details. (Paper Book Page no-46-71). We are also enclosing Bank book ... Prashan Tholia Rs. 417667/-, Kanchan Jewelle Corporation Rs. 575010 and milin Gems Rs. 1169440/- We are enclosing herewith copies of account of Trade creditors in the books of M/s Pansari gems Corporation showing the payment details. (Paper Book Page no-72-84) We are also enclosing Bank book of Pansari

Uma Strips Limited, Delhi vs. ACIT, Circle-27(1), Delhi

In the result, appeal of the assessee in ITA No

ITA 2507/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Neeraj Mangla, CAFor Respondent: Ms. Pooja Swaroop, CIT- DR
Section 115BSection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 68

from assessee and by way of issuance of notices u/s 133(6) of the Act from the related trade creditors. Not being satisfied by the response of the Page 4 of 11 [A.Y 2017-18] Uma Strips Ltd vs ACIT creditors, who replied from a common email and filed similar ... residential property and this loan was extended to the assessee. 12. With respect to ground 4, the ld AR vehemently argued that the trade creditors are all family members with whom the assessee had an MoU for commodities contracts on silver and copper as the assessee was a member

Shri Naval Kishore Singh, Jammu vs. Deputy Commissioner of Income Tax Circle-1, Jammu

In the result, the ground of appeal No

ITA 376/ASR/2023[2014-15]Status: DisposedITAT Amritsar15 Dec 2025AY 2014-15

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Joginder Singh, C. A
Section 144Section 250Section 44A

31st March 2013 , and the closing capital on the said date is also worked out after adjustment of liabilities ( including bank loans and trade creditors) leaving a closing capital balance of Rs.2,54,03,505/- as on 31st March, 2013, which is the brought forward balance as on 1st April

Subhash Jaiswal Associates, Bareilly vs. PCIT Bareilly, Bareilly

ITA 100/LKW/2022[2017-18]Status: DisposedITAT Lucknow11 Dec 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Respondent by
Section 143(3)Section 263

assessee was scrutinized and assessment was completed. Thereafter, Commissioner noticed that AO had not conducted proper enquiry to verify cash credit entries and trade creditors- He exercised his jurisdiction u/s 263 and remanded matter to AO- Assessee filed writ petition against the order. Records showed that AO did not verify ... genunineness of trade creditors and assessment order was completely silent and bereft of any discussion on material points- Whether, therefore, assessment order was erroneous and prejudicial to interest of Revenue. Held, yes. It was further held by the Hon'ble Court that "The Commissioner may consider an order

Proton Positive Health Care India Private Limited, Hyderabad vs. ACIT., Circle -16(2), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 812/HYD/2025[2016-17]Status: DisposedITAT Hyderabad03 Dec 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.812/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Proton Positive Health Vs. Assistant Commissioner Care India Private Limited, Of Income Tax, Hyderabad. Circle-16(2), Pan: Aafcp6862K Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Date Of 03/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) (For Short, “Cit(A)”) Dated 07/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 271(1)(C) Of The Income-Tax Act, 1961 (For Short, “Act”) Dated 28/06/2019 For Ay 2016-17. The Assessee Has Assailed The Impugned Order Passed By The Cit(A) On The Following Grounds Of Appeal Before Us:

For Appellant: Shri M.V. Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(1)Section 271(1)Section 271(1)(c)Section 56(2)(viib)

that there was no compliance. 4. On the facts and circumstances of the case, the Assessing Officer has made the addition with respect to trade creditors which is already recorded in the Books of accounts, and it does not tantamount to furnishing inaccurate particulars of income which leads to penalty

Alicon Castalloy Ltd, Pune vs. PCIT, -1, Pune

In the result, appeal of the Assessee is allowed

ITA 1377/PUN/2025[2020-21]Status: DisposedITAT Pune14 Nov 2025AY 2020-21

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1377/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Alicon Castalloy Ltd., V The Pr.Commissioner Of Gat No.1426, Village S Income Tax-1, Pune. Shikrapur, Taluka Shirur, Pune – 412208. Pan: Aabcp0252B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak Revenue By Shri Aditya Shukla – Cit(Dr) Date Of Hearing 17/09/2025 Date Of Pronouncement 14/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1, Under Section 263 Of The Income Tax Act, 1961 Dated 27.03.2025 For Assessment Year 2020-21 Emanating From The Assessment Order U/S.143(3) Of The Act, Dated 20.09.2022. The Assessee Has Raised The Following Grounds Of Appeal : “1] The Learned Pr.C1T Erred In Revising The Asst, Order Passed U/S

Section 143(3)Section 263

revising the asst, order u/s 263 by setting aside the asst. order to the file of the learned A.O. to reexamine the issue of trade creditors without appreciating that the asst, order was neither erroneous nor prejudicial to the interest of the revenue and therefore, there was no reason ... said issue. 3] The learned Pr. CIT erred in setting aside the asst, order with a direction to reexamine the issue of trade creditors without giving any opportunity to the assessee and therefore, the revision order passed u/s 263 is invalid in law and the same may be declared null