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“unexplained expenditure”

Cash Credits & Unexplained ItemsSection 69CSection 69C3,276 judgments

RAMESHKUMAR KARSANBHAI PATEL,SURAT vs. ITO, WARD 2(3)(5), SURAT

Accordingly the estimated addition made of Rs.35,166/-[0.5% of 70,33,182/-] by the AC invoking provision of section 69C of the I.T Act stand deleted. Thus this ground is allowed

ITA 669/SRT/2025[2015-16]Status: DisposedITAT Surat09 Apr 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 10(38)Section 115Section 115BSection 250Section 68Section 69C

unable either to establish any basis of estimation how he estimated the said 0.5% commission and not 5% or 6 оr 10% commission of unexplained expenditure for the said transaction or the AO is unable to bring any cogent materials of 0.5% expenditure incurred by the appellant before invoking provision

THE SIMALIYA DUDH UTPADAK SAHAKARI MANDLI LIMITED,PANCHMAHAL vs. THE ITO, WARD-1, GODHRA

In the result, the appeal of the assessee is partly allowed

ITA 2442/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri M K Patel, AdvocateFor Respondent: Smt. Ananya Kulshresth, Sr. DR
Section 147Section 234ASection 250(6)Section 270ASection 69C

members, thereby casting doubt on the genuineness of the claim. Accordingly, the Assessing Officer treated the cash withdrawals of Rs. 26,17,000/- as unexplained expenditure under section 69C of the Act and also added interest income of Rs. 10,107/- under the head “Income from Other Sources”, determining ... Assessing Officer in treating the The Simaliya Dudh Utpadak Sahakari Mandli Ltd. vs. ITO Asst. Year –2019-20 - 4– cash withdrawals as unexplained expenditure and confirming the addition of interest income, and accordingly dismissed all the grounds of appeal. 5. The assessee is in appeal before us against the order

S.S. INDUSTRIES, RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Appeals of the assessee are allowed for statistical purposes as above

ITA 817/RPR/2025[2020-21]Status: DisposedITAT Raipur20 Mar 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 816 & 817/Rpr/2025 (िनधा"रण वष" Assessment Years: 2019-20 & 2020-21) S.S. Industries, Plot No.610, 611, Vs Assistant Commissioner Of Income- 620, 621, Urla Industrial Area, Village- Tax, Central Circle 1, Raipur, Central Accholi, Distt.-Raipur, C.G.-492003 Revenue Building, Raipur, C. G. Pan: Aclfs9015L (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. राज" की ओर से / Revenue By : Shri Raghunath, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/03/2026 घोषणा की तारीख / Date Of : 20/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

For Appellant: NoneFor Respondent: Shri Raghunath, CIT-DR
Section 139Section 142(1)Section 143(2)Section 153CSection 250Section 250(6)Section 69C

case and in law, the Ld. Commissioner of Income-tax (Appeals), Raipur-3 has erred in confirming addition of Rs.1,82,84,253/- as unexplained expenditure u/s.69C of the Income-tax Act, 1961 without considering facts of the case in its entirety and without incriminating material. 5. The impugned order ... case and in law, the Ld. Commissioner of Income-tax (Appeals), Raipur-3 has erred in confirming addition of Rs.1,82,84,253/- as unexplained expenditure u/s.69C of the Income-tax Act, S.S. Industries, Raipur vs. ACIT, Central Circle-1, Raipur 1961 without considering facts of the case

S.S. INDUSTRIES, RAIPUR,RAIPUR vs. ACIT, CENTRAL CIRCLE-1, RAIPUR, RAIPUR

Appeals of the assessee are allowed for statistical purposes as above

ITA 816/RPR/2025[2019-20]Status: DisposedITAT Raipur20 Mar 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 816 & 817/Rpr/2025 (िनधा"रण वष" Assessment Years: 2019-20 & 2020-21) S.S. Industries, Plot No.610, 611, Vs Assistant Commissioner Of Income- 620, 621, Urla Industrial Area, Village- Tax, Central Circle 1, Raipur, Central Accholi, Distt.-Raipur, C.G.-492003 Revenue Building, Raipur, C. G. Pan: Aclfs9015L (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : None. राज" की ओर से / Revenue By : Shri Raghunath, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 17/03/2026 घोषणा की तारीख / Date Of : 20/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am:

For Appellant: NoneFor Respondent: Shri Raghunath, CIT-DR
Section 139Section 142(1)Section 143(2)Section 153CSection 250Section 250(6)Section 69C

case and in law, the Ld. Commissioner of Income-tax (Appeals), Raipur-3 has erred in confirming addition of Rs.1,82,84,253/- as unexplained expenditure u/s.69C of the Income-tax Act, 1961 without considering facts of the case in its entirety and without incriminating material. 5. The impugned order ... case and in law, the Ld. Commissioner of Income-tax (Appeals), Raipur-3 has erred in confirming addition of Rs.1,82,84,253/- as unexplained expenditure u/s.69C of the Income-tax Act, S.S. Industries, Raipur vs. ACIT, Central Circle-1, Raipur 1961 without considering facts of the case

ITO, LUDHIANA vs. ARUN GUPTA, LUDHIANA

ITA 112/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh19 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am आयकरअपीलसं./ Ita No.112/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Ito Arun Gupta बनाम/ Vs. Aayakar Bhawan, Rishi Nagar 1698 – New Shakti Nagar, Ludhiana, Punjab - 141001 Ludhiana, Punjab - 141001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Abkpg-4933-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. B.M. Monga & Sh. Rohit Kaura (Advocates) ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 21-01-2026 घोषणाकीतारीख /Date Of Pronouncement 19-03-2026 : आदेश / O R D E R Krinwant Sahay () This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Cit(A)/Nfac, Delhi, Dated 04.12.2024, Pertaining To The Assessment Year 2021-22. The Revenue Has Challenged The Action Of The Ld. Cit(A) In Setting Aside The Assessment Order To The File Of The Assessing Officer For Fresh Adjudication.

For Appellant: Sh. B.M. Monga & Sh. Rohit Kaura (Advocates)For Respondent: Sh. Manav Bansal (CIT) Ld. DR
Section 143(2)Section 144Section 144BSection 251Section 68Section 69C

Income Tax (Appeals) has failed to appreciate the fact that the addition of Rs. 4,13,73,219/- made by the AO being unexplained expenditure u/s 69C r.w.s. 115BBE of the Income Tax Act, 1961 on account of 25% of the unverified purchases and the assessee had failed to furnish

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1392/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

form of additional evidences submitted in course of the appellate proceedings and deleting the addition of Rs. 5,00,000/- on account of unexplained expenditure without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 6. On the facts ... circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 5,00,000/- on account of unexplained expenditure ignoring the fact that out of cheque and cash transaction in excel sheet seized during the search, cheque transactions were recorded in the books

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1278/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

form of additional evidences submitted in course of the appellate proceedings and deleting the addition of Rs. 5,00,000/- on account of unexplained expenditure without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 6. On the facts ... circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 5,00,000/- on account of unexplained expenditure ignoring the fact that out of cheque and cash transaction in excel sheet seized during the search, cheque transactions were recorded in the books

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

ITA 1277/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Mar 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

Section 250Section 68

form of additional evidences submitted in course of the appellate proceedings and deleting the addition of Rs. 5,00,000/- on account of unexplained expenditure without remanding the matter to the Assessing Officer which in clear violation of the Rule 46A of the Income Tax Rules. 6. On the facts ... circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 5,00,000/- on account of unexplained expenditure ignoring the fact that out of cheque and cash transaction in excel sheet seized during the search, cheque transactions were recorded in the books

DCIT CENTRAL CIRCLE -28, NEW DELHI, NEW DELHI vs. MANOJ KUMAR SINGH, NEW DELHI

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

ITA 8069/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 132ASection 153DSection 28

partly confirming the additions amounting to INR 16,27,32,260/- under various heads (including unaccounted cash, sale of gold and scrap, unaccounted commission, unexplained expenditure) under Section 69, Section 69A and Section 69C of the Act. Originally, the Ld. AO had aggregated a much higher total addition ... calculation instead of completely deleting the same. The addition is based on incorrect facts, unreliable and unsubstantiated data, retracted statements rendering it legally unsustainable. Unexplained Expenditure (INR 11,87,34,210) 10.5. Because the Ld. CIT (A) has erred in law and on the facts of the case in considering

MANOJ KUMAR SINGH,DELHI vs. DCIT(A) CENTRAL CIRCLE-28, DELHI

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

ITA 6383/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 132ASection 153DSection 28

partly confirming the additions amounting to INR 16,27,32,260/- under various heads (including unaccounted cash, sale of gold and scrap, unaccounted commission, unexplained expenditure) under Section 69, Section 69A and Section 69C of the Act. Originally, the Ld. AO had aggregated a much higher total addition ... calculation instead of completely deleting the same. The addition is based on incorrect facts, unreliable and unsubstantiated data, retracted statements rendering it legally unsustainable. Unexplained Expenditure (INR 11,87,34,210) 10.5. Because the Ld. CIT (A) has erred in law and on the facts of the case in considering

INCOME TAX OFFICER WARD 6 (1), MOHALI vs. SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, KHRAR PUNJAB

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1217/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

facts and in law, the CIT(A) was justified in deleting the addition of Rs.2,02,41,851/- made on account of unexplained expenditure merely on the basis that the same was reflected as “pre-operative expenses” in the balance sheet, without verification of supporting vouchers, bills, OR other documentary ... loans were added to assessee’s income u/s 68 of the Act. 2.5 Another addition as made by Ld. AO was on account of unexplained expenditure which stem from the fact that the assessee deposited cash of Rs.351.40 Lacs which was sourced out of earlier withdrawals for Rs.644.40 Lacs

SKYCITY BUILDERS AND PROMOTERS PRIVATE LIMITED, ,KHARAR, RUPNAGAR vs. DCIT WARD 6(1), CHANDIGARH JAO ITO 6(1) MOHALI, CHANDIGARH

In the result, the corresponding grounds as raised by the revenue stand dismissed

ITA 1066/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh16 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.1066/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Skycity Builders & Promoters Pvt. Ltd. Dcit Ward 6(1) बनाम/ Room No.3, 1St Floor Sco-90, City Heart Kharar-Chandigarh Road, Livestock Complex Vs. Kharar, Rupnagar (Punjab) - 140301 Sector – 68, Mohali -160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं./ Ita No.1217/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit Ward 6(1) M/S Skycity Builders & Promoters Pvt. Ltd. बनाम/ Room No.3, 1St Floor Sco-90, City Heart Livestock Complex Kharar-Chandigarh Road, Vs. Sector – 68, Mohali -160062 Kharar, Rupnagar (Punjab) - 140301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aapcs-2435-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Ms. Yamini (Cit) - Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 05.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.03.2026

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Ms. Yamini (CIT) - Ld. DR (Virtual)
Section 143(3)Section 148Section 68

facts and in law, the CIT(A) was justified in deleting the addition of Rs.2,02,41,851/- made on account of unexplained expenditure merely on the basis that the same was reflected as “pre-operative expenses” in the balance sheet, without verification of supporting vouchers, bills, OR other documentary ... loans were added to assessee’s income u/s 68 of the Act. 2.5 Another addition as made by Ld. AO was on account of unexplained expenditure which stem from the fact that the assessee deposited cash of Rs.351.40 Lacs which was sourced out of earlier withdrawals for Rs.644.40 Lacs

ACIT,CIRCLE -20(1),MUMBAI, MUMBAI vs. UTKARSHA VIVEK PARKAR, MUMBAI

In the result appeal filed by the Revenue is dismissed

ITA 6513/MUM/2025[2011-12]Status: DisposedITAT Mumbai16 Mar 2026AY 2011-12

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokaracit Circle-20(1), Utkarsha Vivek Mumbai Parkar, Room No. 305, 3Rd Vs. 108, A-Wing, Byculla Floor, Piramal Service Industrial Chambers, Parel, Estate, D. K. Cross Mumbai – 400 012. Road, Byculla, Mumbai-400 027 Pan/Gir No. Agjpp4377J (Applicant) (Respondent) Revenue By Shri Nayanjyoti Nath, Ld. Dr Assessee By Ms. Dinkle Hariya, Ld. Ar Date Of Hearing 11.03.2026 Date Of Pronouncement 16.03.2026

Section 133(6)Section 143(1)Section 143(3)Section 147Section 148Section 250Section 271(1)(c)Section 69C

assessee had obtained accommodation entries in the form of bogus purchase bills and treated the entire amount of Rs. 28,28,113/- as unexplained expenditure under section 69C of the Act. The said amount was added to the total income of the assessee. Consequently, the total income was assessed ... aforesaid judicial precedents of the Hon’ble jurisdictional High Court, the action of the Assessing Officer in treating the entire purchases as unexplained expenditure under section 69C of the Act was justified. 13. We have carefully considered the rival submissions of both the parties and perused the material available

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI DEEPAK MOHANLAL PURSWANI, RAJKOT

ITA 665/RJT/2024[2022-23]Status: DisposedITAT Rajkot13 Mar 2026AY 2022-23
For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 147Section 250

moment\nassessee's income is being assessed at 8% of the gross on-money, then the\nremaining amount 92% could take care of unexplained expenditure. It can be\nexplained by a simple, viz. an assessee has received Rs.100/- in cash for sale of\nflat. Out of that, element of income

NISHA RANI,C/O SAHAY ENTERPRISES vs. THE INCOME TAX OFFICER, WARD -1(2), AAYAKAR BHAWAN,

In the result, this appeal of the assessee is partly allowed

ITA 434/GTY/2025[2020-2021]Status: DisposedITAT Guwahati13 Mar 2026AY 2020-2021

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumarnisha Rani, I.T.O., Bedi Market, At Road, Ward-1(2), Vs. Guwahati-781001 (Assam) Guwahati. (Appellant) (Respondent) Pan No. Afjpr 7852 P Assessee By : Shri Vishesh Surana, Fca. Revenue By : Shri Santosh Kumar Karnani, Addl. Cit Date Of Hearing: 09/03/2026 Date Of Pronouncement: 13/03/2026 O R D E R

For Appellant: Shri Vishesh Surana, FCAFor Respondent: Shri Santosh Kumar Karnani, Addl
Section 142(1)Section 145(3)Section 147Section 148Section 148ASection 69C

affirmed the order of the Assessing Officer by holding that the addition of bogus purchases was rightly 3 Nisha Rani Vs ITO made as unexplained expenditure under Section 69C as the Assessing Officer has concrete information in his possession that the supplier is engaged in providing fake/fictitious GST invoices

INCOME TAX OFFICER, DINDIGUL vs. KRISHNASAMY KARTHIKEYAN, DINDIGUL

In the result, appeal filed by the Revenue is dismissed

ITA 2959/CHNY/2025[2018]Status: DisposedITAT Chennai13 Mar 2026

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: Mr.Krishnasamy KarthikeyanFor Respondent: Ms. R. Anitha, Addl.CIT
Section 148Section 250Section 69ASection 69C

Krishnasamy Karthikeyan :: 3 :: made addition of ₹1,09,80,930/- u/s.69A of the Act [unexplained money] and ₹2,83,500/- u/s.69C of the Act [unexplained expenditure]. Thus, made a total addition of ₹1,17,08,540/- in place of Returned Income of ₹4,44,110/-. Aggrieved, the assessee preferred ... withdrawal. So he made addition of ₹1,09,80,930/- u/s.69A of the Act [unexplained money] and ₹2,83,500/- u/s.69C of the Act [unexplained expenditure]. Thus, made a total addition of ₹1,17,08,540/- in place of Returned Income of ₹4,44,110/-. On appeal, the Ld.CIT

DCIT, CIRCLE 2(1), TRICHY STATIONED AT THANJAVUR, THANJAVUR vs. SRI BHUVANESVARI THANGAMALIGAI, PUDUKKOTTAI

In the result, appeal filed by the Revenue is dismissed

ITA 2915/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Respondent: Ms.R. Anitha, Addl.CIT
Section 133ASection 68

relevant to assessment year concerned, in which the assessee is found to be the owner of such money, bullion, jewellery or valuable article or unexplained expenditure, if, the such expenditure or such money etc., are not recorded in the books of accounts, if any, maintained by assessee for any source

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. YAGNIK ROAD HIGHSTREET LLP, RAJKOT

Appeal of the revenue is dismissed:\n(i)Ground no

ITA 684/RJT/2024[2021-22]Status: DisposedITAT Rajkot12 Mar 2026AY 2021-22
For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147

been\nasked as to why the addition of Rs.4,34,40,484/-should not be made in the hands\nof the firm being unexplained expenditure. In response, the assessee has\nsubmitted following reply -\n\"We have received your show cause notice dated 29-12-2022, proposing ... account of unexplained expenditure u/s 69C of the Act.\nIn the notice, your honor has stated that even in the hands of the partners the funds\nwere not sufficient to make their respective payments for alleged purchase of the land.\nWe once again reiterate that complete on-money cannot

YAGNIK ROAD HIGHSTREET LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Appeal of the revenue is dismissed:\n(i)Ground no

ITA 512/RJT/2024[2021-22]Status: DisposedITAT Rajkot12 Mar 2026AY 2021-22
For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147

been\nasked as to why the addition of Rs.4,34,40,484/-should not be made in the hands\nof the firm being unexplained expenditure. In response, the assessee has\nsubmitted following reply -\n\"We have received your show cause notice dated 29-12-2022, proposing ... account of unexplained expenditure u/s 69C of the Act.\nIn the notice, your honor has stated that even in the hands of the partners the funds\nwere not sufficient to make their respective payments for alleged purchase of the land.\nWe once again reiterate that complete on-money cannot

YAGNIK ROAD HIGHSTREET LLP,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Appeal of the revenue is dismissed:\n(i)Ground no

ITA 511/RJT/2024[2020-21]Status: DisposedITAT Rajkot12 Mar 2026AY 2020-21
For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147

been\nasked as to why the addition of Rs.4,34,40,484/-should not be made in the hands\nof the firm being unexplained expenditure. In response, the assessee has\nsubmitted following reply -\n\"We have received your show cause notice dated 29-12-2022, proposing ... account of unexplained expenditure u/s 69C of the Act.\nIn the notice, your honor has stated that even in the hands of the partners the funds\nwere not sufficient to make their respective payments for alleged purchase of the land.\nWe once again reiterate that complete on-money cannot

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