Protective Cash Credit Addition Unsustainable Without Ownership Evidence: ITAT Delhi

ACIT Vs Ambarnuj Finance and Investments Pvt Ltd. (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, dismissed the Revenue’s appeals and upheld the deletion of protective additions made under Section 68 of the Income-tax Act for Assessment Years 2015–16 and 2016–17. The dispute concerned additions of ₹7.35 crore and ₹27.06 crore, respectively, treated by the Assessing Officer as unexplained cash credits. These additions were made on a “protective” basis, with the allegation that the assessee was part of an accommodation entry network controlled by certain operators. Th...