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ITA No. 3415/Mum/2025 & CO No. 268/Mum/2025 (A.Y. 2014-15)

Case No: ITA No. 3415/Mum/2025 & CO No. 268/Mum/2025
Court: INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI
Date: 1/29/2026

Parties Involved

RevenueAsst. CIT-32(1)
AssesseeSuman Gandhi

Facts Summary

The assessee, Suman Gandhi, is a resident individual who derives income from salary, business, investment, dividend, etc. For the assessment year 2014-15, she declared an income of Rs.21,34,700/-. The Assessing Officer (A.O.) received information from the Serious Fraud Investigation Office (SFIO) alleging that some brokers, including the assessee, had indulged in fraudulent activities by manipulating share transactions through Client Code Modification. Based on this report, the A.O. reopened the assessment and added an amount of Rs.3,05,75,681/- as unexplained cash credit under section 68 of the Income Tax Act, 1961. The assessee contested this addition, providing details of her commodity transactions and a letter from her broker admitting that the Client Code Modification was done without her instructions.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the addition of Rs.3,05,75,681/- as unexplained cash credit u/s. 68 of the Act on account of Client Code Modification is justified.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

4 precedents cited in this judgement.

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ITA No. 3415/Mum/2025 & CO No. 268/Mum/2025 (A.Y. 2014-15) | ITA No. 3415/Mum/2025 & CO No. 268/Mum/2025 | 20… | Opakhya