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Facts
The assessee's appeal for assessment year 2012-13 challenges the finding that credit card bills of Rs.6,17,121/- paid to M/s CITI and HSBC Bank were unexplained under section 69C of the Act. The assessee submitted that these payments were made from her bank accounts, which also reflected her salary income.
Held
The Tribunal observed that the assessee's submission that the payments were made through her bank accounts was not rebutted by the Revenue. Consequently, the addition made under section 69C was deleted.
Key Issues
Whether credit card payments made through bank accounts, supported by salary income, can be treated as unexplained under Section 69C of the Income-tax Act, 1961?
Sections Cited
69C, 147
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 21.01.2026 Date of pronouncement 21.01.2026 ORDER This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2023-24/1056734449(1), dated 03.10.2023 involving proceedings under section 147 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
It emerges during the course of hearing that the assessee’s sole substantive ground raised herein challenges both the learned lower authorities’ respective findings treating her credit card bills of Rs.6,17,121/- paid to M/s CITI and HSBC Bank as unexplained under section 69C of the Act; in assessment order dated 12.12.2019 and upheld in the lower appellate discussion.
That being the case, learned counsel invites the tribunals attention that not only the assessee has been held as to have derived salary income of Rs.13,40,640/- but also she has enclosed her bank statement indicating that both these payments had been made through the said bank accounts only than involving any cash payments. All these factual averments have gone unrebutted from the Revenue side. I Accordingly delete the impugned section 69C addition of Rs.6,17,121/- in very terms.