RACHIT AGGARWAL (PROP.) ASHOK KUMAR GUPTA & CO.,LUDHIANA vs. ITO, WARD II(2), LUDHIANA

In the result, appeal of the assessee is allowed

Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)

unexplained cash credit’ under section 68 of the Act. Thereby, the addition made u/s 68 in respect of unexplained cash

SANJEEV KUMAR GOYAL,FATEHABAD vs. DCIT, CC-2, LUDHIANA

In the result, the appeal of the assesse is allowed

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

unexplained cash credit under section 68 of the Act can be considered for set-off against losses under various heads

ASSISTANT COMMISSIONER OF INCOME TAX, CHANDIGARH vs. SARAF THE JEWELLERS, PUNJAB

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

Section 115BBE of the difference of the alleged cost of construction is not sustainable. 5. That CIT(A) has erred in making the addition of Rs.2,07,40,000/- on account of unsecured loan u/s 68 and applying the provisions of Sec.115BBE of the Income Tax Act and this addition was not called for as no incriminating evidence in respect

SARAF THE JEWELLER, CHANDIGARH,CHANDIGARH vs. THE DCIT/ACIT CENTRAL CIRCLE -2, CHANDIGARH, CHANDIGARH

Appeal stand dismissed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

Section 115BBE of the difference of the alleged cost of construction is not sustainable. 5. That CIT(A) has erred in making the addition of Rs.2,07,40,000/- on account of unsecured loan u/s 68 and applying the provisions of Sec.115BBE of the Income Tax Act and this addition was not called for as no incriminating evidence in respect

SH.RAJINDER MITTAL,PANCHKULA vs. ACIT, CHANDIGARH

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

unexplained cash credit u/s 68 on the basis of Bank statement. As in replied by the assessee that section 68

ACIT, CENTRAL CIRCLE -1,, LUDHIANA vs. M/S OSWAL APPARELS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

unexplained cash credit u/s 68 of the Act was not justified and the same is directed to be deleted. The appeal of the assessee company on Grounds No.1 & 2 are treated as allowed. Ground no. 3 is general in nature, which does not require adjudication. 6. In the result, the appeal of the assessee is treated as allowed

ACIT -CENTRAL CIRCLE-1,, LUDHIANA vs. M/S OSWAL TRENDS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

unexplained cash credit u/s 68 of the Act was not justified and the same is directed to be deleted. The appeal of the assessee company on Grounds No.1 & 2 are treated as allowed. Ground no. 3 is general in nature, which does not require adjudication. 6. In the result, the appeal of the assessee is treated as allowed

ACIT, CENTRAL CIRCLE -1,, LUDHIANA vs. M/S OSWAL APPARELS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

unexplained cash credit u/s 68 of the Act was not justified and the same is directed to be deleted. The appeal of the assessee company on Grounds No.1 & 2 are treated as allowed. Ground no. 3 is general in nature, which does not require adjudication. 6. In the result, the appeal of the assessee is treated as allowed

ACIT -CENTRAL CIRCLE-1,, LUDHIANA vs. M/S OSWAL TRENDS PVT. LTD., LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

unexplained cash credit u/s 68 of the Act was not justified and the same is directed to be deleted. The appeal of the assessee company on Grounds No.1 & 2 are treated as allowed. Ground no. 3 is general in nature, which does not require adjudication. 6. In the result, the appeal of the assessee is treated as allowed

M/S OSWAL TREND (P) LTD.,LUDHIANA vs. DCIT, C. C.-1, LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

unexplained cash credit u/s 68 of the Act was not justified and the same is directed to be deleted. The appeal of the assessee company on Grounds No.1 & 2 are treated as allowed. Ground no. 3 is general in nature, which does not require adjudication. 6. In the result, the appeal of the assessee is treated as allowed

M/S OSWAL APPARELS PVT. LTD.,LUDHIANA vs. DCIT, C.C.- 1, LUDHIANA

In the result, this appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Shri Krinwant Sahay

unexplained cash credit u/s 68 of the Act was not justified and the same is directed to be deleted. The appeal of the assessee company on Grounds No.1 & 2 are treated as allowed. Ground no. 3 is general in nature, which does not require adjudication. 6. In the result, the appeal of the assessee is treated as allowed

SWARN GANGA JEWELLERS,CHANDIGARH vs. DCIT, CIRCLE 4(1) NOW DCIT, CIRCLE 1(1), CHANDIGARH

In the result, the appeal of the assessee stands allowed

Bench: This Tribunal Being Aggrieved By An Order No. Itba/Nfac/S/250/2022-23/1045180258(1) For A.Y. 2017-18 Dt. 05/09/2022 Which Is Hereinafter Referred To As The “Impugned Order”. The Impugned Order Is Passed By Cit(A) In Terms Of Section 250 Of The Income Tax Act, 1961. Factual Matrix 2. That Survey U/S 133A Of The Income Tax Act, 1961 Was Conducted On The Business Premises Of The Assessee On 06/09/2016. The Assessee Surrendered A Sum Of Rs. 50,00,000/- During The Survey & Paid Tax Thereon. The Return Of Income Was Filed On 01/11/2017 Declaring A Total Income Of Rs. 89,48,260/-. Thereafter The Case Of The Assessee Was Selected For Scrutiny Under Compulsory Scrutiny Guidelines & Notice Under Section 143(2) Of The Act Was Issued On 11/09/2018. The Assessment Was Finalised Vide Order Dt. 23/12/2019 Whereby Addition Of Rs. 95,70,882/- Was Made U/S 68 R.W..S 115Bbe Of The Act.

unexplained cash sales is deemed income u/s 68 of the Act as the appellant could not establish the genuineness of the same and the income assessed u/s 68 is liable to be taxed as per the provisions of section 115BBE of the Act. Therefore, this case falls squarely under the ambit of section 115BBE of the Act as applicable w.e.f

USHA RANI,PANCHKULA vs. INCOME TAX OFFICER, WARD-5,, PANCHKULA

In the result, the appeal of the assessee is allowed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

unexplained cash credit applying the provisions of Section 68 r/w Section 115BBE which is arbitrary and unjustified. 2. That the Ld. Commissioner

INCOME TAX OFFICER, CHANDIGARH vs. SANBIR SINGH, CHANDIGARH

In the result, the appeal is dismissed

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

68 of the Income Tax Act. Therefore, the sum of Rs.40.00.000/- is treated as unexplained cash credited added to the total income of the assessee. Accordingly tax on such unexplained income is computed as per the provisions of section

INDERJIT SINGH BRAR,PATIALA vs. INCOME TAX OFFICER, PATIALA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav

Cash credits. 68. Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof or the explanation offered by him is not in the opinion of the Assessing Officer, satisfactory, the sum so credited may be charged to income

RAJIV GOYAL, PATIALA,PATIALA, PUNJAB vs. JAO ITO WARD-3, PATIALA, PATIALA

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

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

68 of the Income-tax Act, 1961 - Cash credit (Scope of provision) - Assessment year 2016-17 - Assessing Officer made addition of certain amount to assessee's income on account of unsecured loan treading same as unexplained 11 cash credit under section

SH. SANDEEP KUMAR,LUDHIANA vs. ITO, WARD-4, KHANNA

In the result, the appeal of the assessee is allowed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

section 68 was wrongly made as it is not a case of unexplained cash credit as no books are maintained

INCOME TAX OFICER, BC BAZAR vs. THE KESRI UNION FARMERS SERVICE CO-OP SOCIETY LTD, AMBALA

In the result appeal of Department / Revenue is dismissed

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

unexplained cash credit u/s 68 of the Act. Accordingly, penalty proceedings under section 271AAC of the Income Tax Act, 1961 have

TARLOCHAN SINGH ,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

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

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

section 115BBE had wrongly invoked. That the Assessing Officer made the addition amounting to Rs.25,961.00 on account of alleged interest earned on the advances to different persons. During the course of survey operation cash was found excess in books of accounts however physical cash was nil and the officer contended that the said cash was advanced to difference persons