TaxTMI 
TaxTMI 
2025 (5) TMI 1969
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....e. VIBHU BAKHRU, J. (ORAL) 1. The Revenue has filed the present appeals, inter alia, impugning a common order dated 20.09.2024 passed by the learned Income Tax Appellate Tribunal [ITAT] in a batch of appeals arising from separate orders passed by the Commissioner of Income Tax (Appeals) 29, New Delhi [CIT(A)], in respect of Assessment Years [AYs] 2012-13 to AY 2017-18. A tabular statement setting out the details of the present appeals for the respective AYs are as under: Item Nos. ITA Nos. Assessment Years Declared Income 17. ITA No. 2413/Del/2024 2012-13 Rs. 1,02,560/- 18. ITA No. 2416/Del/2024 2015-16 Rs. 3,49,901/- 19. ITA No. 2417/Del/2024 2016-17 Rs. 3,49,901/- 20. ITA No. 2418/Del/2024 2017-18 Rs. 54,888/- 21. ....
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.... as a conduit for routing accommodation entries. The Jain Brothers were using the Assessee as their vehicle routing funds to the ultimate beneficiaries. The amounts were credited in the accounts of the Assessee and thereafter paid to the other entities under the control of the Jain Brothers, which in turn had transmitted the same to the ultimate beneficiaries. The Assessee was used to layer the funds, which were received in cash and introduced in other companies under the control of the Jain Brothers for onward payment to the ultimate beneficiaries. 4. In the aforesaid circumstances, the amounts, which were credited in the bank accounts of the Assessee were added as unexplained credits under Section 68 of the Act. The AO also reasoned that....
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....ent appeals, we do not find any infirmity in the decision of learned first appellate authority in deleting the additions. Grounds are dismissed." 7. In the aforesaid context, the Revenue has projected a similar set of questions for consideration of this Court, albeit with varied amounts. We consider it apposite to set out the questions of law as projected in ITA No. 137/2025 in respect of AY 2012-13. The same are set out below: "A. Whether on the facts & in the circumstances of the case, the Hon'ble ITAT has erred in law & on facts by deleting the addition of Rs. 9,54,01,729/- made on account of undisclosed sources u/s 68 for unexplained entries in bank account ignoring the fact that assessee has failed to produce any concrete and any ad....
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....f the Assessee during different financial years. The said tabular statement is set out below: Sr No Name of the Assessee/Company Bank Name A/c no FY Credit Balance Debit Balance 14 Third Generation Traders Pvt. Ltd. HDFC Bank 13478470000061 2011-12 8,78,82,934.00 8,77,95,000.00 HDFC Bank 2012-13 13,03,58,676.00 13,04,45,708.00 HDFC Bank 2013-14 9,10,42,513.00 9,09,78,059.18 HDFC Bank 2014-15 7,17,31,282.00 7,16,85,000.00 HDFC Bank 2015-16 25,80,59,142.00 25,81,62,970.68 HDFC Bank 2016-17 9,81,43,905.00 9,76,79,582.00 HDFC Bank 2017-18 12,18,51,126.00 12,21,35,980.00 10. The above tabular statement clearly indicates that the Assessee's opening balances and closing balances are substantially the same. Th....