Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalm/S A-One Enterprises, Income Tax Officer, 135/61 East Patel Nagar, Dehradun. Dehradun, Uttarakhand-248001. Vs. Pan-Aanfa5222D (Appellant) (Respondent) Assessee By Shri Saurabh Gupta, Ca Department By Shri A. S. Rana, Sr. Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 18.02.2026 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)’ In Short], Dated 25.08.2025 In Appeal No. Cit(A)/Dehradun/10654/2019-20 Arising Out Of The Assessment Order Passed U/S 143(3) Of The Act, 1961 (The Act’ In Short) Dated 16.12.2029 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Had Filed Its Return Of Income Declaring Total Income At Rs.3,08,939/-. The Case Was Selected For Scrutiny & Assessment Was Completed Vide Order Dated 16.12.2019 At A Total Income Of Rs.51,79,869/- By Making Additions Of Rs.48,49,500/- U/S 68 Of The Act & Rs.21,430/- U/S 41(1) Of The Act. A-One Enterprises Vs. Ito 3. Aggrieved By The Said Order, The Assessee Preferred An Appeal Before The Ld. Cit(A) Who Partly Allowed The Appeal By Allowing The Additions Of Rs.4,49,500/- After Verification By The Ao & Confirmed The Remaining Additions Of Rs. 44.00 Lacs Made U/S 68 Of The Act & Rs. 21,430/- Towards Bogus Liability.

unexplained cash credit u/s 68 of the Act. Claim of the assessee was that the amount was contributed by Shri Surendra Kumar Goyal, partner out of the funds borrowed from his wife Smt. Anita Goyel of Rs. 35.00 lacs, received back A-One Enterprises vs. ITO loan earlier given to one M/s Allied Marketing of Rs. 4.25 lacs and remaining