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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

Kcc Buildtech Private Ltd., New Delhi vs. DCIT, Central Circle-4, New Delhi

In the result, all the appeals filed by the assessee are allowed

ITA 1688/DEL/2023[2010-11]Status: DisposedITAT Delhi07 Jun 2024AY 2010-11

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Us

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Ms. Rajinder Kaur, CIT DR
Section 132Section 153ASection 153CSection 68Section 69C

Assessing officer has erred in law and facts while making addition u/s 69C amounting to Rs. 1,00,000/- as unexplained expenditure of the appellant company on account of accommodation entries whereas no such commission was paid as the issue of share capital was a genuine transaction despite the fact

ACIT, Central Circle-18, New Delhi vs. Aqua Electronic & Solutions P.Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 3685/DEL/2018[2010-11]Status: DisposedITAT Delhi04 Jun 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2010-11 Acit, Vs Aqua Electronic & Solutions P. Ltd., Central Circle-18, 239, Okhla Industrial Estate, New Delhi. Phase-3, New Delhi. Pan: Aahca4306R (Applicant) (Respondent) Assessee By : Shri S. Krishnan, Advocate Revenue By : Mrs. Sunita Verma, Cit, Dr Date Of Hearing : 05.03.2024 Date Of Pronouncement : 04.06.2024

For Appellant: Shri S. Krishnan, AdvocateFor Respondent: Mrs. Sunita Verma, CIT, DR
Section 143Section 143(3)Section 147Section 153ASection 68Section 69C

Rs.125,77,00,000/- on account of unexplained share capital/share premium/share application money was made u/s 68 and Rs.2,51,54,000/- as unexplained expenditure u/s 69C of the Act were deleted by the ld.CIT(A) for which the Revenue is in appeal raising the following grounds:- “1. Whether ... Commissioner of Income Tax (Appeals) has erred in deleting the addition of Rs.2,51,54,000/- made by the A.O. on account of unexplained expenditure on Brokerage/Commission paid by assessee company. 4. Whether on the facts and circumstances of the case and in law the Ld. Commissioner of Income

Ketan Harilal Mehta HUF by Its Karta Ketan H Mehta, Mumbai vs. ITO Ward-33(2)(2) Mumbai Presently Juridiction With ITO 42(1)(1) Mumbai, Mumbai

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

ITA 770/MUM/2023[2014-15]Status: DisposedITAT Mumbai03 Jun 2024AY 2014-15

Bench: Shri B R Baskaran & Shri Pavan Kumar Gadaleketan Harilal Mehta Huf Vs. Ito-42(1)(1), (By Its Karta Kautilya Bhavan, Ketanmehta)No.B/1101, Bkc,Bandra(E), Siddhi Vinayak Tower, Mumbai-400051. Opp Phoenix Hospital, Chikuwadi, Mumbai-400092. Pan/Gir No. : Aaehk3266N Appellant .. Respondent Appellant By : Shri. Nishit Gandhi.Ar Respondent By : Shri. P.D. Chougule.Sr.Dr Date Of Hearing 02.04.2024 Date Of Pronouncement 03.06.2024 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac)(Cit(A)) Delhi Passed U/Sec 143(3) & U/Sec250 Of The Income Tax Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Nishit Gandhi.ARFor Respondent: Shri. P.D. Chougule.Sr.DR
Section 10(38)Section 68Section 69C

making an addition of Rs.75,391/- being alleged Ketan Harilal Mehta, HUF,Mumbai. commission on the sale of shares and treating the same as unexplained expenditure u/s 69C of the Act. 4.2. While doing so, the Ld. CIT(A) failed to appreciate that the said addition

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

ITA 797/JPR/2023[2018-19]Status: DisposedITAT Jaipur30 May 2024AY 2018-19
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”A” JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

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

ITA 796/JPR/2023[2017-18]Status: DisposedITAT Jaipur30 May 2024AY 2017-18
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

erred on facts and in law in making addition of Rs. 96,000/- on account of interest paid by treating the same as unexplained expenditure u/s 69C of the Act and taxing the same u/s 115BBE of the Act by ignoring that source of such payment is advance and interest ... further made addition of Rs.5,43,000/- in AY 2012-13 to 2015-16 by treating the interest paid on loan received as unexplained expenditure u/s 69C of the Act and tax the same u/s 115BBE of the Act. 7. Before the Ld. CIT(A) assessee submitted the amended summary

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

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

ITA 795/JPR/2023[2016-17]Status: DisposedITAT Jaipur30 May 2024AY 2016-17
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

erred on facts and in law in making addition of Rs. 96,000/- on account of interest paid by treating the same as unexplained expenditure u/s 69C of the Act and taxing the same u/s 115BBE of the Act by ignoring that source of such payment is advance and interest ... further made addition of Rs.5,43,000/- in AY 2012-13 to 2015-16 by treating the interest paid on loan received as unexplained expenditure u/s 69C of the Act and tax the same u/s 115BBE of the Act. 7. Before the Ld. CIT(A) assessee submitted the amended summary

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

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

ITA 794/JPR/2023[2015-16]Status: DisposedITAT Jaipur30 May 2024AY 2015-16
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

erred on facts and in law in making addition of Rs. 96,000/- on account of interest paid by treating the same as unexplained expenditure u/s 69C of the Act and taxing the same u/s 115BBE of the Act by ignoring that source of such payment is advance and interest ... further made addition of Rs.5,43,000/- in AY 2012-13 to 2015-16 by treating the interest paid on loan received as unexplained expenditure u/s 69C of the Act and tax the same u/s 115BBE of the Act. 7. Before the Ld. CIT(A) assessee submitted the amended summary

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

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

ITA 793/JPR/2023[2014-15]Status: DisposedITAT Jaipur30 May 2024AY 2014-15
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

erred on facts and in law in making addition of Rs. 96,000/- on account of interest paid by treating the same as unexplained expenditure u/s 69C of the Act and taxing the same u/s 115BBE of the Act by ignoring that source of such payment is advance and interest ... further made addition of Rs.5,43,000/- in AY 2012-13 to 2015-16 by treating the interest paid on loan received as unexplained expenditure u/s 69C of the Act and tax the same u/s 115BBE of the Act. 7. Before the Ld. CIT(A) assessee submitted the amended summary

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

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

ITA 792/JPR/2023[2013-14]Status: DisposedITAT Jaipur30 May 2024AY 2013-14
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

erred on facts and in law in making addition of Rs. 96,000/- on account of interest paid by treating the same as unexplained expenditure u/s 69C of the Act and taxing the same u/s 115BBE of the Act by ignoring that source of such payment is advance and interest ... further made addition of Rs.5,43,000/- in AY 2012-13 to 2015-16 by treating the interest paid on loan received as unexplained expenditure u/s 69C of the Act and tax the same u/s 115BBE of the Act. 7. Before the Ld. CIT(A) assessee submitted the amended summary

Sh. Gopal Singh Sunda, Sikar vs. DCIT, Central Circle-2, Jaipur

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

ITA 791/JPR/2023[2012-13]Status: DisposedITAT Jaipur30 May 2024AY 2012-13
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Arvind Kumar (CIT)
Section 127Section 132Section 133ASection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153CSection 69C

erred on facts and in law in making addition of Rs. 96,000/- on account of interest paid by treating the same as unexplained expenditure u/s 69C of the Act and taxing the same u/s 115BBE of the Act by ignoring that source of such payment is advance and interest ... further made addition of Rs.5,43,000/- in AY 2012-13 to 2015-16 by treating the interest paid on loan received as unexplained expenditure u/s 69C of the Act and tax the same u/s 115BBE of the Act. 7. Before the Ld. CIT(A) assessee submitted the amended summary

Agrasen Primses Private Limited, Jaipur vs. ITO Ward 5(1), Jaipur

ITA 125/JPR/2023[2014-15]Status: DisposedITAT Jaipur30 May 2024AY 2014-15
For Appellant: Ms. Parba Rana (Adv.)&For Respondent: Shri A.S. Nehra (CIT)
Section 133ASection 142(1)Section 143(2)Section 143(3)

raised by the appellant are found to be not acceptable and the addition made by AO with regard to disallowance of bogus loss and unexplained expenditure on commission paid for procuring these entries of loss is found to be justified. Therefore, the order of the AO is confirmed. This ground

Bhumika Rajesh Vatnani, Mumbai vs. 24(1)(1), Mumbai

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

ITA 204/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 May 2024AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2012-13

For Appellant: Mr. Ashok Kumar Ambastha, Sr. DRFor Respondent: Ms. Ridhisha Jain
Section 10(38)Section 68

Infra Venture Ltd as unexplained sale of shares of Wagend Infra Venture Ltd as unexplained sale of shares of Wagend Infra Venture Ltd as unexplained expenditure u/s 69C of the IT act 1961 and expenditure u/s 69C of the IT act 1961 and the reasons assigned the reasons assigned

Shaily Prince Goyal, Mumbai vs. Income Tax Officer-27(3)(1), Navi Mumbai

In the result, the appeal of the assessee Shri Yogesh Popatlal Thakkar in ITA No

ITA 4271/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 May 2024AY 2013-14
For Appellant: Dr. K Shivaram Sr. Advocate & Shashi BekalFor Respondent: Ms. Sujatha Iyangar SR AR
Section 10(38)Section 143(3)Section 148Section 250Section 68Section 69C

entries in the nature of LTCG they charge commission ranging from 4% 6%, thus 6% of the sale consideration is being taken as the unexplained expenditure incurred by the assessee for arranging the accommodation entries. 15.5.2 In view of the above facts it is crystal clear that the assessee utilized ... undisclosed income and, hence, an amount of Rs. 50,46,247/- (6% of Rs. 8,41,04,109/-) is taxed as unexplained expenditure u/s 69C of the Income Tax Act, 1961. Alternatively, this amount also represents the undisclosed income or income from undisclosed sources of the assessee for the previous

Prime Vision Industtries Pvt. Ltd., New Delhi vs. DCIT Circle 5(2)(1), Noida

In the result, the appeal is allowed for statistical purposes

ITA 75/DEL/2024[2014-15]Status: DisposedITAT Delhi30 May 2024AY 2014-15

Bench: Shri G.S. Pannu, Vice- & Shri Anubhav Sharmaassessment Year: 2014-15

Section 147Section 69C

Vaishno Devi Exim. and accordingly examined the case of assessee. Additions under Section 69C of the Act on account of cash credits and unexplained expenditure were made which were challenged before the learned First Appellate Authority. 2. During the course of hearing, it has come up that amongst other grounds

Ankur Agrawal, Bhopal vs. NFAC, Delhi

In the result the appeals of the assessee are allowed for

ITA 21/IND/2024[2013-14]Status: DisposedITAT Indore29 May 2024AY 2013-14

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

Section 142(1)Section 144Section 147Section 148Section 250Section 271Section 69C

quashed. 5. That on the facts and circumstances of the case the Learned CIT Appeals erred in confirming the addition on account of unexplained expenditure under section 69C Rs.19,33,300/- 6. That the above grounds are independent to each other. 2. At the time of hearing Ld. AR submitted ... quashed. 5. That on the facts and circumstances of the case the Learned CIT Appeals erred in confirming the addition on account of unexplained expenditure under section 271(1)(c ) at Rs.4,22,290/- 6. That the above grounds are independent to each other. 7. Since the matter in quantum

Ankur Agrawal, Barkheda Bhopal vs. NFAC, Delhi

In the result the appeals of the assessee are allowed for

ITA 18/IND/2024[2013-14]Status: DisposedITAT Indore29 May 2024AY 2013-14

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

Section 142(1)Section 144Section 147Section 148Section 250Section 271Section 69C

quashed. 5. That on the facts and circumstances of the case the Learned CIT Appeals erred in confirming the addition on account of unexplained expenditure under section 69C Rs.19,33,300/- 6. That the above grounds are independent to each other. 2. At the time of hearing Ld. AR submitted ... quashed. 5. That on the facts and circumstances of the case the Learned CIT Appeals erred in confirming the addition on account of unexplained expenditure under section 271(1)(c ) at Rs.4,22,290/- 6. That the above grounds are independent to each other. 7. Since the matter in quantum

Viren Panchand Vora HUF Through Karta Bimal V Vora, Mumbai vs. Income Tax Officer, Ward 19(3)(5), Mumbai

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

ITA 283/MUM/2024[2008-09]Status: DisposedITAT Mumbai29 May 2024AY 2008-09

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhariassessment Year: 2008-09

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

order dated 09.03.2016 under section 143(3) of the Act made the addition of Rs.3,36,026/- under section 69C of the Act, as unexplained expenditure. 3. The assessee, being aggrieved, challenged the said addition by filing first appeal. First appellate authority during the appellate proceedings though issued various notices

Kishore Ghevarchand Jain, Mumbai vs. DCIT, Circle-1, Kalyan

In the result, the appeal is allowed in aforesaid terms

ITA 278/MUM/2024[2015-16]Status: DisposedITAT Mumbai29 May 2024AY 2015-16

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2015-16 Mr. Kishor Ghevarchand Jain Circle -1, Kalyan D.C.I.T. 3Rd Floor, 1St Floor, Porwal Bhawan, Mohan Plaza, Vs. Near Vaishya Mandir Hall, Wayale Nagar, Kasarhat, Kalyan Khadak Pada, Thane - 421301. Kalyan (W.) - 421301. Pan: Aazpj6248E (Appellant) (Respondent) Present For: Assessee By : Shri Bhupendra Shah, A.R. Revenue By : Shri P. D. Chougule (Addl. Cit), Sr. D.R. Date Of Hearing : 13 . 05 . 2024 Date Of Pronouncement : 29 . 05 . 2024 O R D E R Per : Ratnesh Nandan Sahay: 1. This Appeal Has Been Filed By The Appellant Against The Order Of The Ld. Cit (Appeals) Passed U/S. 250 Of The Income Tax Act [The „Act‟ In Short] Vide Its Din & Order No. Itba/ Nfac/S/250/2023-24/1057548827(1) Dated 31/10/2023 For The Assessment Year 2015-16. 2. The Following Ground Of Appeal Have Been Raised:

For Appellant: Shri Bhupendra Shah, A.RFor Respondent: Shri P. D. Chougule (Addl. CIT), Sr. D.R
Section 143(3)Section 147Section 234BSection 250Section 271(1)(c)Section 5Section 69Section 69C

circumstances of the case and in law, the learned Assessing Officer erred in making addition of Rs.2.40,218/- u/s. 69C of the Act as unexplained expenditure incurred for alleged non genuine transactions in consequence to aforesaid addition without any proof of such expenditure being incurred which is a prerequisite

Suresh Maheshwari HUF, Mumbai vs. Dy. Commissioner on Income-Tax-25(1), Mumbai

In the result, the appeal is allowed

ITA 3904/MUM/2023[2014-15]Status: DisposedITAT Mumbai29 May 2024AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2014-15 M/S. Suresh Maheshwari Huf Dy. Commissioner Of 431, Akshay Girikunj, Income –Tax-25(1), Bldg.- 3, Parliament Road, Vs. Room No. 206, 2Nd Floor, Matru Mandir, Andheri (West) – 400058. Andheri Railway Station S.O. Tardeo Road, Pan: Aabhs3934A Mumbai- 400007. (Appellant) (Respondent) Present For: Assessee By : Shri Rajesh Shah, C.A. Revenue By : Shri Prashant Mahajan, Sr. D.R. Date Of Hearing : 07 . 05 . 2024 Date Of Pronouncement : 29 . 05 . 2024 O R D E R Per : Ratnesh Nandan Sahay: 1. These Appeals Have Been Filed By The Appellant Against The Order Of The Ld. Cit (Appeals) Passed U/S. 250 Of The Income Tax Act [The „Act‟ In Short] Dated 21/09/2023 For The Assessment Year 2014-15. 2. The Following Grounds Have Been Raised In Ita No. 3904/M/ 2023:-

For Appellant: Shri Rajesh Shah, C.AFor Respondent: Shri Prashant Mahajan, Sr. D.R
Section 10(38)Section 143(1)Section 148Section 250Section 68Section 69

confirming the addition made by Ld. AO for 2,21,845/-on account estimation of commission being 3 percent of ₹ 73,94,850/- as unexplained expenditure. 4. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 3. The facts of the case, in brief ... being 3% of the sale value of Rs.73,94,850/- was also added u/s. 69 C of the Income Tax Act as unexplained expenditure on account of commission paid for arranging the entire transactions of bogus LTCG. 6. The Ld. CIT Appeal upheld the order of the assessing officer

Suresh Maheshwari HUF, Mumbai vs. Dy. Commissioner on Income-Tax-25(1), Mumbai

In the result, the appeal is allowed

ITA 3903/MUM/2023[2015-16]Status: DisposedITAT Mumbai29 May 2024AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahayassessment Year: 2015-16 M/S. Suresh Maheshwari Huf Dy. Commissioner Of 431, Akshay Girikunj, Income –Tax-25(1), Bldg.- 3, Parliament Road, Vs. Room No. 206, 2Nd Floor, Matru Mandir, Andheri (West) – 400058. Andheri Railway Station S.O. Tardeo Road, Pan: Aabhs3934A Mumbai- 400007. (Appellant) (Respondent) Present For: Assessee By : Shri Rajesh Shah, C.A. Revenue By : Shri Prashant Mahajan, Sr. D.R. Date Of Hearing : 07 . 05 . 2024 Date Of Pronouncement : 29 . 05 . 2024 O R D E R Per : Ratnesh Nandan Sahay: 1. These Appeals Have Been Filed By The Appellant Against The Order Of The Ld. Cit (Appeals) Passed U/S. 250 Of The Income Tax Act [The „Act‟ In Short] Dated 21/09/2023 For The Assessment Year 2015-16. 2. The Following Grounds Have Been Raised In Ita No. 3903 Of 2023 Are As Under:

For Appellant: Shri Rajesh Shah, C.AFor Respondent: Shri Prashant Mahajan, Sr. D.R
Section 10(38)Section 143(1)Section 143(2)Section 250Section 68Section 69Section 69C

confirming the addition made by Ld. AO for ₹ 1,98,321/- on account estimation of commission being 3 percent of ₹ 66,10,708/- as unexplained expenditure. 4. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal. 3. The facts of the case, in brief ... being 3% of the sale value of Rs.66,10,708/- was also added u/s. 69C of the Income Tax Act as unexplained expenditure on account of commission paid for arranging the entire transactions of bogus LTCG. 5. The Ld. CIT Appeal upheld the order of the assessing officer on account