DAR E IMAAN WELFARE AND EDUCATIONAL TRUST,VELLORE vs. ITO, EXEMPTION WARD,, CHENNAI
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the expenditure incurred for stationery and books, supported by vouchers acknowledged by the recipient, cannot be treated as unexplained expenditure. The order of the CIT(A) was found to be not justified.
What were the facts?
The assessee's appeal was against an order confirming the disallowance of a deduction and treating it as unexplained expenditure. The Assessing Officer added an amount for unexplained expenditure based on the absence of evidence.
What were the issues?
Whether the disallowance of expenditure as unexplained under Section 69C of the Income Tax Act, 1961, is justified when supported by vouchers.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Before: Shri M. Balaganesh & Shri S.S. Viswanethra Ravi
Year: 2019-20 DAR E Imaan Welfare and Educational Vs. The Income Tax Officer, Trust, No. 434/1, G. Kayide Millath Exemption Ward, Nagar, Kathiyavadi, Melvisharam, Chennai. Vellore 632 509. [PAN: AACTD2327B] (अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ� की ओर से / Appellant by : None ��थ� की ओर से/Respondent by : Shri C.P. Solomon, JCIT सुनवाई की तारीख/ Date of hearing : 22.10.2025 घोषणा की तारीख /Date of Pronouncement : 28.10.2025 आदेश /O R D E R
PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:
This appeal filed by the assessee is directed against the order dated 11.07.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2019-20.
When the appeal was taken up for hearing, none appeared on behalf of the assessee nor filed any adjournment petition. Hence we proceed to hear the ld. DR, pass order on merits taking in consideration the material available on record.
The assessee raised 6 grounds of appeal amongst which, the only issue emanates for our consideration as to whether the ld. CIT(A) is justified in confirming the disallowance of claim of deduction and treating the same as unexplained expenditure under section 69C of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances of the case.
4. It is noted that the Assessing Officer added an amount of Rs.2,23,149/- under section 69C of the Act on account of unexplained expenditure in the absence of any evidence to that effect which is clear from paras 1 and 2 of the assessment order. In the first appellate proceedings, the ld. CIT(A) vide para 5.1 of the impugned order discussed the issue and held the evidence adduced by the assessee referring to page 17 of the impugned order, which was held to be in the form of self-made vouchers, not sufficient in support of the contention of the assessee relating to the impugned addition. On perusal of the same, i.e., the sample vouchers, which were reproduced in page 17 of the impugned order, it is noted that the said expenditure incurred for purchase of stationery and books for the purpose of assessee’s business approved and acknowledged by the recipient, which clearly shows that the said expenditure from the books. Therefore, we are of the opinion that holding the same as self-made vouchers by the ld. CIT(A) is not tenable, cannot be held to be unexplained expenditure under section 69C of the Act. Thus, the order of the ld. CIT(A) is not justified, the addition confirmed thereon, is deleted. Grounds raised by the assessee are allowed.
In the result, the appeal filed by the assessee is allowed. Order pronounced on 28th October, 2025 at Chennai.
More judgments on Section 69C
- Jitendrakumar Bhikhabhai Shrimali, Mehsana vs ITO Ward 1, MehsaanaITA 1290/AHD/2026[2017-18]Status: Disposed21 Oct 2026AY 2017-18
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- Mritunjay Singh, Kudra vs AO, SasaramITA 454/PAT/2026[2017-2018]Status: Disposed16 Oct 2026AY 2017-2018
- Shantilal Mafaji Kachchhava, Banaskantha vs ITO WD 1 Palanpur, PalanpurITA 2256/AHD/2026[2023-24]Status: Disposed16 Oct 2026AY 2023-24
- Madhusudhan Gade, Nizamabad vs ITO., Ward-1, NizamabadITA 379/HYD/2025[2017-18]Status: Disposed16 Oct 2026AY 2017-18
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