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“unexplained expenditure”

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

The decision most relied on for unexplained expenditure is CIT v. Bholanath Poly Fab. Pvt. Ltd. (355 ITR 290), cited in 712 judgments on BharatTax.

Leading authorities on unexplained expenditure

CIT v. Bholanath Poly Fab. Pvt. Ltd.
355 ITR 290 · 2013 · High Court
712
citing judgments

If an assessee makes purchases from bogus parties, but the underlying goods are genuinely acquired and sold, only the profit margin embedded in such purchases, and not the entire value of the bogus purchases, should be added to the assessee's income.

Vijay Proteins Ltd. v. Asst. CIT
58 ITD 428 · 1996 · ITAT
430
citing judgments

Where purchases are found to be non-genuine or fictitious, a reasonable disallowance of 25% of such purchases or the peak credit, whichever is higher, can be made. This is applied to address unexplained expenditure under Section 69C when actual goods are likely procured from the grey market.

Nikunj Eximp Enterprises v. CIT
216 Taxmann 171 · 2013 · High Court
325
citing judgments

Purchases may be treated as genuine even if the purchase parties are untraceable or not available for verification, as long as there is no specific evidence from the parties themselves denying the transactions or proving them to be bogus.

CIT v. M.K. Brothers
163 ITR 249 · 1987 · High Court
262
citing judgments

Mere non-production of a party or their denial of a transaction is insufficient to treat a payment as non-genuine if it is duly recorded in books and made through banking channels. Once the assessee furnishes relevant documentation, the burden shifts to the Assessing Officer to prove the transaction is not genuine.

N.K. Proteins Ltd. v. DCIT
84 Taxmann.com 195 · 2017 · Supreme Court
204
citing judgments

When purchases are found to be entirely bogus and based on fictitious invoices from non-existent or unconfirmed suppliers, the entire amount of such purchases is liable to be added back as unexplained expenditure, not merely a percentage thereof.

CIT v. La Medica
250 ITR 575 · 2001 · High Court
150
citing judgments

When purchases are shown to be non-genuine, the entire amount is to be disallowed as unexplained expenditure under section 69C, irrespective of whether the goods were procured from alternative sources.

Vijay Proteins Ltd. v. CIT
58 Taxmann.com 44 · 2015 · High Court
140
citing judgments

When an assessee makes alleged bogus or hawala purchases but subsequently makes genuine sales from those purchases, the addition to income should be restricted only to the estimated profit embedded in such transactions, not the entire purchase value.

N.K. Industries Ltd. v. DCIT
72 Taxmann.com 289 · 2016 · High Court
127
citing judgments

When there is a categorical finding that purchases are bogus and from fictitious suppliers, the Assessing Officer is justified in making a 100% addition of the bogus purchase amount under Section 69C, rather than restricting the disallowance to merely the profit margin. This position has been upheld by the Supreme Court through the dismissal of the assessee's SLP.

Judgments citing unexplained expenditure

Naresh Manakchand Jain, Mumbai vs. ACIT 2(1), Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 247/MUM/2023[2011-12]Status: DisposedITAT Mumbai27 Jun 2024AY 2011-12

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale

For Appellant: Shri Sucheck Anchaliya &For Respondent: Shri S. Srinivasu, CIT-DR
Section 132Section 144Section 153ASection 69C

erred in confirming the addition made by the Assessing Officer amounting to Rs.1,71,046/- out of Rs.3,59,713/- as unexplained expenditure u/s 69C of Income Tax Act, 1961. Relief Claimed” Addition made by the AO and confirmed by the CIT(A) amounting to Rs.1,71,046/- should ... However, the assessee has not explained the source of the same with supporting documents. Accordingly, the same is added to the total income as unexplained expenditure u/s. 69C. Having regard to the nature of addition I am satisfied that the concealed the particulars of his income and therefore penalty proceedings

Naresh Manakchand Jain, Mumbai vs. ACIT 2(1), Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 244/MUM/2023[2017-2018]Status: DisposedITAT Mumbai27 Jun 2024AY 2017-2018

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale

For Appellant: Shri Sucheck Anchaliya &For Respondent: Shri S. Srinivasu, CIT-DR
Section 132Section 144Section 153ASection 69C

erred in confirming the addition made by the Assessing Officer amounting to Rs.1,71,046/- out of Rs.3,59,713/- as unexplained expenditure u/s 69C of Income Tax Act, 1961. Relief Claimed” Addition made by the AO and confirmed by the CIT(A) amounting to Rs.1,71,046/- should ... However, the assessee has not explained the source of the same with supporting documents. Accordingly, the same is added to the total income as unexplained expenditure u/s. 69C. Having regard to the nature of addition I am satisfied that the concealed the particulars of his income and therefore penalty proceedings

Naresh Manakchand Jain, Mumbai vs. ACIT 2(1), Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 243/MUM/2023[2016-2017]Status: DisposedITAT Mumbai27 Jun 2024AY 2016-2017

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale

For Appellant: Shri Sucheck Anchaliya &For Respondent: Shri S. Srinivasu, CIT-DR
Section 132Section 144Section 153ASection 69C

erred in confirming the addition made by the Assessing Officer amounting to Rs.1,71,046/- out of Rs.3,59,713/- as unexplained expenditure u/s 69C of Income Tax Act, 1961. Relief Claimed” Addition made by the AO and confirmed by the CIT(A) amounting to Rs.1,71,046/- should ... However, the assessee has not explained the source of the same with supporting documents. Accordingly, the same is added to the total income as unexplained expenditure u/s. 69C. Having regard to the nature of addition I am satisfied that the concealed the particulars of his income and therefore penalty proceedings

Naresh Manakchand Jain, Mumbai vs. ACIT 2(1), Mumbai

ITA 242/MUM/2023[2015-2016]Status: DisposedITAT Mumbai27 Jun 2024AY 2015-2016

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale

For Appellant: Respondent byFor Respondent: Date of Hearing
Section 132Section 144Section 153ASection 69C

erred in confirming the addition made by the Assessing Officer amounting to Rs.1,71,046/- out of Rs.3,59,713/- as unexplained expenditure u/s 69C of Income Tax Act, 1961. Relief Claimed" Addition made by the AO and confirmed by the CIT(A) amounting to Rs.1,71,046/- should ... However, the assessee has not explained the source of the same with supporting documents. Accordingly, the same is added to the total income as unexplained expenditure u/s. 69C. Having regard to the nature of addition I am satisfied that the concealed the particulars of his income and therefore penalty proceedings

Naresh Manakchand Jain, Mumbai vs. ACIT-2(1), Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 241/MUM/2023[2014-2015]Status: DisposedITAT Mumbai27 Jun 2024AY 2014-2015

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale

For Appellant: Shri Sucheck Anchaliya &For Respondent: Shri S. Srinivasu, CIT-DR
Section 132Section 144Section 153ASection 69C

erred in confirming the addition made by the Assessing Officer amounting to Rs.1,71,046/- out of Rs.3,59,713/- as unexplained expenditure u/s 69C of Income Tax Act, 1961. Relief Claimed” Addition made by the AO and confirmed by the CIT(A) amounting to Rs.1,71,046/- should ... However, the assessee has not explained the source of the same with supporting documents. Accordingly, the same is added to the total income as unexplained expenditure u/s. 69C. Having regard to the nature of addition I am satisfied that the concealed the particulars of his income and therefore penalty proceedings

Naresh Manakchand Jain, Mumbai vs. ACIT-2(1), Mumbai

In the result, the appeals of the assessee are partly allowed

ITA 240/MUM/2023[2013-2014]Status: DisposedITAT Mumbai27 Jun 2024AY 2013-2014

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadale

For Appellant: Shri Sucheck Anchaliya &For Respondent: Shri S. Srinivasu, CIT-DR
Section 132Section 144Section 153ASection 69C

erred in confirming the addition made by the Assessing Officer amounting to Rs.1,71,046/- out of Rs.3,59,713/- as unexplained expenditure u/s 69C of Income Tax Act, 1961. Relief Claimed” Addition made by the AO and confirmed by the CIT(A) amounting to Rs.1,71,046/- should ... However, the assessee has not explained the source of the same with supporting documents. Accordingly, the same is added to the total income as unexplained expenditure u/s. 69C. Having regard to the nature of addition I am satisfied that the concealed the particulars of his income and therefore penalty proceedings

Saravanan Palaniappan, Chennai vs. ACIT Central Circle 2(4), Chennai

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 931/CHNY/2024[2021-22]Status: DisposedITAT Chennai26 Jun 2024AY 2021-22

Bench: Hon’Ble Shri Manu Kumar Giri, Jm & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 931/Chny/2024 िनधा"रण वष"/Assessment Year: 2021-2022 Saravanan Palaniappan, The Assistant Commissioner Of 45/21, Poes Garden, Vs. Income Tax, Teynampet, Central Circle 2(4) Chennai 600 086. Chennai. Pan: Ayepp 4761H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Venkata Raman, C.A. ""यथ" क" ओर से/Respondent By : Shri. V. Nandakumar, Irs, Cit. सुनवाई क" तारीख/Date Of Hearing : 24.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.06.2024 आदेश /O R D E R Per Manu Kumar Giri () This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)[Cit(A)] Chennai-19 Dated 21.02.2024 For Assessment Year 2021-22. 2. Assessee Is An Individual & Has Filed The Return Of Income. A Search Was Conducted In The Case Of Kallal Group On 11.03.2021. During Assessment Proceedings Assessee Failed To Explain Sources For The Expenditure, Loan, Investment Etc.. Therefore, The Ao Has Passed Order Under Section 144 Of The Income Tax Act, 1961 (In Short ‘Act’) Dated 27.09.2022 & Made Various Additions & Assessed The Income At Rs.81,58,86,115/- Which Includes Unexplained Expenditure, Unexplained Cash, Unexplained Loan, Unexplained Investment In Gold Jewellery & Silvers Items & Income From Other Sources.

For Appellant: Shri. R. Venkata Raman, C.AFor Respondent: Shri. V. Nandakumar, IRS, CIT
Section 144

Income Tax Act, 1961 (In short ‘Act’) dated 27.09.2022 and made various additions and assessed the income at Rs.81,58,86,115/- which includes unexplained expenditure, unexplained cash, unexplained loan, unexplained investment in gold jewellery and silvers items and income from other sources. 3. Further, the appellant filed the appeal

Pradeepshetty, Tirupur vs. ITO, Ward-2, Tirupur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 674/CHNY/2024[2017-18]Status: DisposedITAT Chennai26 Jun 2024AY 2017-18

Bench: Shri Mahavir Singh & Shri Jagadishआयकर अपील सं./Ita No.674/Chny/2024 िनधा9रण वष9 /Assessment Year: 2017-18

Section 144Section 147Section 69ASection 69C

Addition of unexplained investment u/s. Rs. 1,84,69,800/- 69A of the Act Addition of unexplained expenditure u/s. Rs. 81,60,453/- 69C of the Act Addition of undisclosed income (interest) Rs.14,13,375/- Addition of unexplained expenditure to Rs. 32,562/- foreign company

Raj Sarathy Jagdish, Thane vs. ITO Ward 3 (2), Thane

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 3850/MUM/2023[2013-14]Status: DisposedITAT Mumbai26 Jun 2024AY 2013-14

Bench: Shri Amit Shukla & Shri Gagan Goyalraj Sarathy Jagdish C/001, Ignis Building Lodha Splendora, Ghodbunder Road, Thane 400 607 Pan: Agppj8217K ..... Appellant Vs. Ito Ward 3(2)/Nfac Ashar It Park, Wagle Estate Thane- 400 604 ..... Respondent

For Appellant: Shri Bhupendra Shah, Ld. ARFor Respondent: Shri R. R. Makwana, Ld. DR
Section 148Section 234ASection 250Section 271(1)Section 69ASection 69C

learned Faceless Assessing Officer erred in making addition of Rs. 10,29,885/- in respect of amount paid for Credit Card Bills as Unexplained expenditure and adding the same u/s. 69C of Income Tax Act, 1961. a. By ignoring the fact that the appellant is not required to maintain Books ... fact that the expenses is paid by the Appellant from disclosed Bank Accounts and out of disclosed source of Income cannot be considered as unexplained expenditures under any circumstances. c. Without considering the fact that this amounts to double taxation of same Income, Firstly under the head Cash deposit

Mindspace Versonal Information, Aurangabad vs. ITO, Ward 1(1), Aurangabad

In the result, the appeal filed by the assessee stands partly allowed for statistical purpose

ITA 612/PUN/2024[2016-17]Status: DisposedITAT Pune25 Jun 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.612/Pun/2024 "नधा"रण वष" /Assessment Year : 2016-17 Mindspace Ventures Limited, Vs. Ito, Ward-1(1), Plot No.4, Jay Nagar, Aurangabad Dashmeshnagar, Aurangabad 431 005 Maharashtra Pan : Aagcm3686H Appellant Respondent

For Appellant: Adjournment application rejectedFor Respondent: Shri Sandeep P. Sathe
Section 139(1)Section 142(1)Section 144Section 148

circumstances, the AO vide order dated 29.05.2023 was constrained to complete the assessment u/s.144 r.w.s147 of the Act, bringing to tax the unexplained expenditure as well as the interest income aggregating to Rs.2,18,46,289/-. 3. Being aggrieved by the above assessment order, the assessee preferred appeal before ... find the ld. CIT(A)/NFAC also without discussing anything on merits of the controversy of the additions made on account of unexplained expenditure as well as interest income, simply dismissed the appeal in limine, which is contrary to settled position of law. It is a trite law that

Anish M. Kacharia (L/H of Late Shri Mukesh L Kacharia), Mumbai vs. I.T.O.-22(2)(3), Mumbai

In the result, the appeal filed by the assessee stands allowed for statistical purposes

ITA 174/MUM/2024[2010-11]Status: DisposedITAT Mumbai25 Jun 2024AY 2010-11

Bench: Shri Narender Kumar Choudhry & Smt Renu Jauhriassessment Year: 2010-11

For Appellant: Shri Devendra Jain, A.RFor Respondent: Shri Nagnath Pasale, D.R
Section 143(3)Section 147Section 250Section 69C

vide order dated 07.03.2016 under section 143(3) read with section 147 of the Act, has made the addition of Rs.21,45,408/- as unexplained expenditure under section 69C of the Act which was challenged by the assessee before the Ld. Commissioner by filing an appeal on 12.04.2016 in physical

Medsonway Soltutions Private Limited, Pune vs. Assistant Commissioner of Income Tax, Circlr-7, Pune

In the result, the appeal filed by the assessee is allowed

ITA 9/PUN/2024[2018-19]Status: DisposedITAT Pune24 Jun 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.09/Pun/2024 "नधा"रण वष" /Assessment Year : 2018-19 Medsonway Solutions Private Limited, Vs. Acit, Circle-7, Building B, Office No.2, Pune Prakash Niwas, H.No.124, Shukrawar Peth, Pune 411 002 Maharashtra Pan : Aajcm3805F Appellant Respondent

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Sandeep P. Sathe
Section 56(2)(viib)Section 69C

hereinafter referred to as ‘the Act”) with which we are not concerned. The AO also made addition of Rs.56,25,056/- as unexplained expenditure u/s.69C of the Act on account of Sales Promotion expenditure debited to the profit and loss account by holding that the appellant had failed to offer ... assessee had debited the expenditure to the profit and loss accounts in the books of account and 3 the question of treating it as unexplained expenditure does not arise placing reliance on the judgment of Hon’ble Delhi High Court in the case of CIT Vs. M/s. Radhika Creation

Samar Biri Factory, Siliguri vs. A.O., Assessment Unit, Bengaluru

In the result, appeal of the assessee is allowed for statistical purposes

ITA 582/KOL/2024[2020-21]Status: DisposedITAT Kolkata24 Jun 2024AY 2020-21

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 582/Kol/2024 Assessment Year: 2020-21 Samar Biri Factory Assessing Officer, Assessment Unit Aurobindopally Vs Siliguri - 734006 [Pan : Aaofs7941N] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sujit Basu & Rajib Mukherjee, Advocate Revenue By : Shri G. Ajay Robin Singh, Jcit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 12/06/2024 घोषणा क" तारीख /Date Of Pronouncement: 24/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre, (Hereinafter The “Ld. Cit(A)”) Dt. 19/02/2024, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For Assessment Year 2020-21. 2. Though The Assessee Has Raised Various Grounds Of Appeal But The Main Contention Of The Assessee Is That On Account Of The Death Of The Key Person Of The Assessee Firm, No One Could Appear Before The Ld. Assessing Officer And, Thereafter When The Appeal Was Filed Before The Ld. Cit(A), The Same Was Dismissed On Account Of Delay In Filing The Appeal. It Was Prayed That Since High Pitched Assessment Has Been Made In The Case Of Assessee By The Ld. Assessing Officer & Assessee Had No Opportunity To Furnish The Details, The Issues On Merits May Be Restored To The File Of The Ld. Assessing Officer For De Novo Adjudication.

For Appellant: Shri Sujit Basu & Rajib Mukherjee, AdvocateFor Respondent: Shri G. Ajay Robin Singh, JCIT, Sr. D/R
Section 139(1)Section 143(2)Section 250Section 36(1)(va)Section 43BSection 69C

death of the partner again compliance could not be made. We further note that the additions made by the ld. Assessing Officer are firstly unexplained expenditure u/s 69C of the Act for the difference in closing balance of the sundry creditors for the current year and preceding year and secondly

Income Tax Officer, Itarsi vs. Nadeem Khan, Pipariya

In the result appeal of the revenue is allowed for statistical purpose

ITA 37/IND/2024[2017-18]Status: DisposedITAT Indore24 Jun 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniito, Shri Nadeem Khan

Section 139Section 142(1)Section 144Section 148Section 69ASection 69C

facts and the circumstances of the case, the CIT(A) is not justified in deleting the addition of Rs. 10051500/- on account of unexplained expenditure u/s 69C of the IT Act, 1961 on the basis of additional evidence submitted by the assessee without following the due procedure required under rule

DCIT (Central), Bhopal vs. Shailendra Sharma, Bhopal

In the result the appeals of the assessee for the Assessment

ITA 305/IND/2023[2015-16]Status: DisposedITAT Indore24 Jun 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 142(1)Section 153A

firm. We also find that the Assessing Officer has not brought on record any cagent material or evidence that the assessee had incurred any unexplained expenditure during the previous year relevant to A.Y. 9018 14 only. We noted that the Assessing Officer himself, at para (159) of his Order

Rakesh Chandranath Sharma, Mumbai vs. ITO-42(3)(2), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 4124/MUM/2023[2015-16]Status: HeardITAT Mumbai24 Jun 2024AY 2015-16

Bench: Ms Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am Rakesh Chandranath Sharma Ito-42(3)(2) 4, Adhikari Bhavan, Kautilya Bhavan, G Block, Near Hotel Classic, Bkc Bandra Kurla Complex, Behind Jain Sweets, Old Nagardas Vs. Bandra (E), Mumbai-400 051 Road, Andheri(E), Mumbai-400 069

For Appellant: Shri Bhupendra ShahFor Respondent: Smt. Mahita Nair
Section 143(1)Section 143(3)Section 250Section 271(1)Section 68

erred in confirming an adhoc addition of Rs.1,94,538/- (being 3% commission on the above Rs.64,84,598/-) by treating it as unexplained expenditure which were duly explained along with supporting during the assessment proceedings. 3. On the facts and in the circumstances of the case ... sale proceeds of shares as unexplained investment and Rs.1,94,538/- being the addition on account of commission for the said transaction as unexplained expenditure. 4. The assessee was in appeal before the first appellate authority where the impugned addition was upheld by the ld. CIT(A). 5. The assessee

Assistant Commissioner of Income Tax - 4(2)(1), Mumbai vs. Iifl Home Finance Limited, Mumbai

In the result, ground no. 4 of the revenue is allowed for statistical purposes

ITA 1297/MUM/2024[2021-22]Status: DisposedITAT Mumbai21 Jun 2024AY 2021-22

Bench: Shri Anikesh Banerjee & Shri Gagan Goyal

For Appellant: Shri Pritesh MehtaFor Respondent: Shri H.M. Bhatt (SR.DR.)
Section 143(3)Section 144BSection 250Section 43BSection 43DSection 69CSection 80M

facts and circumstances of the case, the Ld CIT (A)/ NFAC is right in deleting the disallowance of Rs.3,41,786/ on account of unexplained expenditure u/s 69C r.w.s. 115BBE? 5) The appellant craves leave to add, amend, alter and/or wiry any of the grounds of appeal before ... Performing Assets) under rule 6EA of I.T Rules, 1962 (in short, ‘the Rules’), payment made to suppliers treated as bogusexpenditure amount to Rs.18,658/-, unexplained expenditure under section 69C Rs.3,41,786/- and disallowance of deduction under section 80M Rs.4,07,13,516/-. Aggrieved, assessee filed an appeal before

Late Radha Kishin Bhatia (Through Leagl Heir Kishin M Bhatia), Mumbai vs. ITO, Int Tax Ward 1(2)1, Mumbai

In the result, ITA No.1084/Mum/2024 is allowed for statistical purposes

ITA 1084/MUM/2024[2012-13]Status: DisposedITAT Mumbai21 Jun 2024AY 2012-13

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: NoneFor Respondent: Shri Anil Sant – Addl.CITDR
Section 144Section 250

sought by the officer is concerned the AO mentioned in the assessment order that why Rs. 3,41,786/- should not be treated as unexplained expenditure in absence of proof of source of payment. 5.1 I have gone through the show cause notice dated 07.12.2022 wherein

Jitendra Udaylal Jain, Maharashtra vs. National Faceless Appeal Centre (NFAC), Delhi

In the result, the appeal filed by the assessee is allowed

ITA 4543/MUM/2023[2011-12]Status: DisposedITAT Mumbai21 Jun 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

Section 10(38)Section 143(1)Section 234ASection 271(1)(c)Section 68Section 69C

commission paid at the rate of 2 per cent on sale of shares by treating it as an unexplained expenditure under section 69C of the income tax act 1961. 4. On the facts and circumstances of the case the Ld AO erred in confirming the interest under section 234A, 234B

Kns Infracon Pvt. Ltd, Delhi vs. DCIT, Circle 14(2), New Delhi

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 3630/DEL/2023[2011-12]Status: DisposedITAT Delhi21 Jun 2024AY 2011-12

Bench: Dr. B. R. R. Kumar, Sh. Anubhav Sharma

For Appellant: Sh. Ruchesh Sinha, AdvFor Respondent: Ms. Parul Singh, Sr. DR
Section 147Section 234Section 69C

facts in making aggregate addition of Rs 7,22,46,923/- on account of alleged bogus expenditure by treating it as alleged unexplained expenditure u/s 69C and that too by recording incorrect facts and findings and without observing the Principles of Natural Justice. (b) That having regard to the facts