Alikhan Mohammad Adilabad Vs ITO (ITAT Hyderabad)
Summary: The appeal was filed by Shri Alikhan Mohammad against the order dated 21.01.2026 passed by the Learned Addl/JCIT(A)-2, Ludhiana for A.Y. 2017-18. The assessee had declared total income of Rs. 3,34,580/- in the return filed on 25.09.2017. In scrutiny assessment under section 143(3), the Assessing Officer made an addition of Rs. 25,622/- towards disallowance of expenditure and Rs. 12,92,305/- towards unexplained cash credits under section 68, assessing total income at Rs. 16,52,507/-. The Addl/JCIT(A) deleted the Rs. 25,622/- disallowance but confirmed the Rs. 12,92,305/- addition.
Before the Tribunal, the assessee contended that the Rs. 12,92,305/- represented advances received against sales from 67 parties and that the advances were subsequently adjusted against sales made to those parties in the immediately succeeding financial year. The Tribunal, however, found that the ledger accounts did not contain postal addresses, PANs or other identification particulars and that no independent documentary evidence had been furnished to establish the identity and creditworthiness of the parties or genuineness of the transactions. The Tribunal also noted that the amounts were generally in the range of Rs. 19,000/- to Rs. 20,000/-, were received in cash, and that in all 67 cases the subsequent sales corresponded exactly with the respective advances. It held that subsequent accounting entries in the assessee’s own books could not, by themselves, establish the genuineness of the original credits. Accordingly, the Tribunal found that the assessee had failed to discharge the onus under section 68 and sustained the addition of Rs. 12,92,305/-.
