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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

Manish Kumar, Kurukshetra vs. Income Tax Officer Ward-1, Kurukshetra

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

ITA 611/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh28 May 2024AY 2018-19

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Dr. Rakesh Gupta, C.A and Mr. Shrey Jain, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 132(1)Section 143(2)Section 147Section 148Section 148ASection 69A

extent of Rs 5,00,000/- is concerned, the assessee has duly discharged his burden and the said expenditure cannot be held as unexplained expenditure as source thereof has been duly explained and substantiated by the assessee in terms of funds received from his mother-in- law. Further, copy ... been duly explained and substantiated and thus, no addition can be made in the hands of the assessee either in terms of unexplained expenditure or in terms of unexplained receipt of funds. 15. Regarding credit of Rs 6,00,000/- in the bank account of the assessee, it is evident

Income Tax Officer-42(1)(2), Mumbai, Kautilya Bhawan vs. Dheeraj Babulal Shah, Mumbai

In the result, appeal of the assessee is allowed

ITA 3320/MUM/2023[2012-13]Status: DisposedITAT Mumbai27 May 2024AY 2012-13

Bench: Shri Narender Kumar Choudhry, Judicialmember & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Rajkumar Singh, CAFor Respondent: Smt. Mahita Nair,Sr. DR
Section 143(3)Section 147Section 148Section 263Section 69Section 69ASection 69C

account of unexplained credit u/s 69C of the Income Tax Act, 1961 being unexplained expenditure? 4. The department has not accepted the decision of Hon'ble ITAT in ITA No.886/Mum/2021 dated 12.12.2022 on which Ld.CIT(A) relied upon and preferred further appeal to Hon'ble Bombay High Court. Therefore

Sanjeev Kumar Goyal, Fatehabad vs. DCIT, CC-2, Ludhiana

In the result, the appeal of the assesse is allowed

ITA 80/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 143(2)Section 250(6)Section 253Section 68

income from 'other sources' because the provisions of sections 69, 69A, 69B and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Therefore ... satisfactorily explained, then, the value of such investments and money or the value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of the assessee. It follows that the moment a satisfactory explanation is given about such nature

Rajiv Kumar Goyal, Dhuri vs. DCIT, CC-2, Ludhiana

In the result, the appeal of the assessee is allowed

ITA 79/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. D.R
Section 133ASection 139(1)Section 250(6)Section 253

income from "other sources" because the provisions of section 69, 69A, 69B and 69C treat unexplained investments, unexplained money, bullion etc. and unexplained expenditure as deemed income where the nature and sources of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained ... Section 69-Unexplained investments, Section 69A-Unexplained money, etc., Section 69B-Amoutn of investments, etc., not fully disclosed in books of account 69C-Unexplained expenditure, etc. and 69D-Amount borrowed or repaid on hundi which have been enacted in the Income Tax Act, 1961. Mentioning of wrong section would

Sh. Baljit Singh, Ludhiana vs. Pr. CIT, Ludhiana -1, Ludhiana

In the result, appeal of the Assessee is dismissed

ITA 416/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh22 May 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Rajiv Kaushal &For Respondent: Shri Rohit Sharma, CIT DR
Section 143(3)Section 263Section 263(1)Section 68Section 92C

assessment by Ld. A.O. The papers supporting the facts of Rs. 1,92,48,027/- LTCG [ not covered by us in this order] and unexplained expenditure of Rs. 1,32,97,887/- [covered by us in this order] submitted during assessment proceedings are hereby again attached.” 7.2 The Ld. PCIT ... where there is addition of Rs. 2,06,85,300/- being the amount on unsecured loan claimed to have been capitalized, as unexplained expenditure under section 69C and further addition of Rs. 36,65,528/- is added being the interest on unsecured loan debited to profit & loss account disallowed under

Felie Amit Bavisi, Navi Mumbai vs. ITO Ward 28(1)(3), Mumbai

In the result, both the appeals filed by the assesse are partly allowed

ITA 507/MUM/2024[2009-10]Status: DisposedITAT Mumbai21 May 2024AY 2009-10

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos. 507 & 508/Mum/2024 (A.Y. 2009-10 & 2010-11) Felie Amit Bavisi Vs Ito-Ward-28(1)(3), Room No. 15B, 610, Thacker Tower Chs, . Aayakar Bhavan, Plot No. 86, M.K.Road, Sector -17 Vashi, Mumbai-400020. Navi Mumbai-400706. Pan/Gir No. Abypb8391E (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 133(6)Section 271(1)(c)Section 69C

received by the party but there is no proper compliance. Further the AO has issued a show cause notice to treat the purchases as unexplained expenditure u/s 69C of the Act. The assessee in response to show cause notice has submitted a letter with details of purchases, invoice copies, confirmation

M/S. Saroj Embrods Pvt. Ltd., Hooghly vs. DCIT, C.C-3(4), Kolkata.

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

ITA 1352/KOL/2023[2016-17]Status: DisposedITAT Kolkata20 May 2024AY 2016-17

Bench: Shri Rajesh Kumar & Shri Sonjoysarma]

Section 143(1)Section 143(3)Section 147Section 148Section 69

tune of Rs. 3.06 crore from these concerns/companies as bogus and added back the same u/s 69 of the Act on account of unexplained expenditure which was claimed by the assessee in the form of purchases in the assessment framed u/s 143(3)/147 of the Act vide order dated ... I.T.A. Nos.1351 & 1352/Kol/2023 Assessment Years: 2015-16 & 2016-17 Saroj Embrods Pvt. Ltd. back the purchases made u/s 69C of the Act as unexplained expenditure. In our opinion, the said view of the AO is full of infirmities and flaws. We note that the provisions of section 69C deals with

Saroj Embrods Private Limited., Hooghly vs. DCIT, C.C-3(4), Kolkata.

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

ITA 1351/KOL/2023[2015-16]Status: DisposedITAT Kolkata20 May 2024AY 2015-16

Bench: Shri Rajesh Kumar & Shri Sonjoysarma]

Section 143(1)Section 143(3)Section 147Section 148Section 69

tune of Rs. 3.06 crore from these concerns/companies as bogus and added back the same u/s 69 of the Act on account of unexplained expenditure which was claimed by the assessee in the form of purchases in the assessment framed u/s 143(3)/147 of the Act vide order dated ... I.T.A. Nos.1351 & 1352/Kol/2023 Assessment Years: 2015-16 & 2016-17 Saroj Embrods Pvt. Ltd. back the purchases made u/s 69C of the Act as unexplained expenditure. In our opinion, the said view of the AO is full of infirmities and flaws. We note that the provisions of section 69C deals with

Sarafathali Mohammed Hasana Lebbai, Mumbai vs. Deputy Commissioner of Income-Tax, Circle 20(1), Mumbai

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

ITA 4825/MUM/2023[2019-20]Status: DisposedITAT Mumbai17 May 2024AY 2019-20

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2019-20

For Appellant: NoneFor Respondent: Shri Rahul Kumar CIT,DR
Section 142(1)Section 144Section 147Section 148Section 234ASection 234BSection 69C

circumstances of the case and in law, the CIT(A) erred upholding the addition of Rs 55,67,87,872 as unexplained expenditure under 2 section 69C of the Act in respect of alleged out of books purchases by the Appellant. 4.2. Without prejudice to the above, on the facts

Sudarshan Anand Sheregar, Vasai vs. CIT(A), Pune-11, Pune

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

ITA 2907/MUM/2023[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amarjit Singh, Sudarshan Anand Vs. Dcit, Central Circle-1 Sheregar, D-1104, Room No.10, A Wing, 6 Th Yashwant Empire, Near Floor, Ashar I.T. Park, Dmart, Off Railway Lines, Road No. 16-Z Wagle Vasai Virar Link Road, Industrial Estate Vasai East, Thane (W) - 400604 Maharashtra – 401209 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Azdps1479H Appellant .. Respondent

For Appellant: Dnyanesh PatadeFor Respondent: Krishna Kumar
Section 132Section 142(1)Section 144Section 153ASection 69ASection 69C

parte u/s 144 of the Act. The assessing officer has made addition of Rs.37,500/- u/s 69C of the Act on account of unexplained expenditure on the basis of notings on a diary seized as bundle no.1 5. The assessing officer has also made addition of Rs.9 ... course of assessment proceedings by the assessing officer. The assessing officer has added Rs.37,500/- u/s 69C of the Act on account of unexplained expenditure on the basis of notings on a diary seized during the search. The assessing officer has also made addition of Rs.9,15,800/- as unaccounted

Sunil Kumar Ravi, Bangalore vs. Assistant Commissioner of Income Tax, Circle-6(1)(1), Bangalore

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

ITA 554/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 May 2024AY 2016-17

Bench: Shri George George K & Shri Waseem Ahmedassessment Year : 2016-17

For Appellant: Shri C Ramesh, CAFor Respondent: Shri Subramanian S, JCIT (DR)

sought an explanation from the assessee but there was no compliance. Thus, the AO added the sum of Rs. 1 crore and unexplained expenditure of Rs. 16,20,590/- to the total income of the assessee. 6. Aggrieved, the assessee preferred an appeal before

Mahavir Polylfilms Private Limited, Mumbai vs. Income Tax Officer, Ward 7(2)(1), Mumbai Or National Faceless E-Assessment Centre, Mumbai

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

ITA 297/MUM/2024[2018-19]Status: DisposedITAT Mumbai16 May 2024AY 2018-19

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan, Mahavir Polyfilms Pvt. Ltd. Vs. Income Tax Officer-7(2)(1) F-10, 7Th Floor, Everest Bldg. Aayakar Bhavan Pandit Madan Mohan Malviya M.K. Road Road, Tardeo, Tulsiwadi Mumbai 400020 Mumbai 400003 Pan/Gir No. : Aagcm1704N Appellant .. Respondent

For Appellant: Shri Mukesh SoniFor Respondent: Shri Sunil Shinde, Sr. A.R
Section 250Section 37

erred in upholding impugned additions of” a. Rs. 3,28,78,700/- being 2 percentage of Material Consumed expenses as alleged in unexplained expenditure. b. Rs. 4,68,841/- under section 37 of the Act which were already added in total income by the Appellant.” 2. At the outset

Aarti Impex, Mumbai vs. Assistant Commissioner of Income Tax 19(1), Mumbai

The appeal of the assessee is partly allowed

ITA 3999/MUM/2023[2012-13]Status: DisposedITAT Mumbai16 May 2024AY 2012-13
Section 143Section 250Section 69C

extent of Rs. 77, 97,761/- (though quantum addition is reduced from Rs. 6, 23, 82,093/-) of the alleged bogus purchases as unexplained expenditure u/s. 69C of the Act even though the impugned transactions were recorded in the duly audited regular books of account of the Appellant

DCIT Central Circle-2(4), Mumbai vs. Ronak Gems Private Limited, Mumbai

In the result, Ground raised by the assessee is allowed

ITA 1497/MUM/2023[2020-221]Status: DisposedITAT Mumbai16 May 2024AY 2020-221

Bench: Shri Amit Shukla & Shri Gagan Goyaldy. Commissioner Of Income Tax, Central Circle- 2(4), Room No. 802, 8Th Floor, Pratistha Bhawan, M.K. Road, Church Gate, Mumbai - 400 020. ...... Appellant Vs. M/S. Ronak Gems Pvt. Ltd., 311, Mehta Bhawan, Shop No. 5, Opp. Charni Road, Mumbai – 400 020. ..... Respondent

For Appellant: Shri Nishit Gandhi, Ld. ARFor Respondent: Smt. Sanyogita Nagpal, Ld. DR
Section 115JSection 143(3)Section 250Section 69ASection 69C

section 69C of the Act (Applied in the case of the assessee on cash purchase) as under: Section - 69C, Income-tax Act, 1961 Unexplained expenditure, etc. 69C. Where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditure ... income of the assessee for such financial year : Provided that, notwithstanding anything contained in any other provision of this Act, such unexplained expenditure which is deemed to be the income of the assessee shall not be allowed as a deduction under any head of income. Now to be precise, this

Hardcore Viniyog P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 573/DEL/2019[2015-16]Status: HeardITAT Delhi16 May 2024AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Mukesh Kumar Jha, CIT-DR
Section 119Section 143(2)

instructions by the CBDT it should be treated as bad in law. The AO has made addition of Rs.39,90,000/- on account of unexplained expenditure by holding that the Sundry Debtors to the extent of Rs. 39,90,000/- as fictitious. 11. The Assessing Officer doubted the Sundry Debtors

Felie Amit Bavisi, Navi Mumbai vs. ITO Ward 28(1)(3), Mumbai

In the result, both the appeals filed by the assesse are partly allowed

ITA 508/MUM/2024[2010-11]Status: DisposedITAT Mumbai15 May 2024AY 2010-11

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawali T A. Nos. 507 & 508/Mum/2024 (A.Y. 2009-10 & 2010-11) Felie Amit Bavisi Vs Ito-Ward-28(1)(3), Room No. 15B, 610, Thacker Tower Chs, . Aayakar Bhavan, Plot No. 86, M.K.Road, Sector -17 Vashi, Mumbai-400020. Navi Mumbai-400706. Pan/Gir No. Abypb8391E (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 133(6)Section 271(1)(c)Section 69C

received by the party but there is no proper compliance. Further the AO has issued a show cause notice to treat the purchases as unexplained expenditure u/s 69C of the Act. The assessee in response to show cause notice has submitted a letter with details of purchases, invoice copies, confirmation

Shri Nilesh Haresh Parwani, Mumbai vs. The Assistant Commissioner of Income Tax-22(2), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 2244/MUM/2023[2014-2015]Status: DisposedITAT Mumbai15 May 2024AY 2014-2015

Bench: Shri Vikas Awasthy & Shri Amarjit Singhshri Nilesh Haresh Vs. The Assistant Parwani, 501, Chumchum Commissioner Of Income Saraswati Road, Tax-22 (2) Santacruz West, Room No. 315, Piramal Mumbai – 400 064 Chamber, Lalbaug, Mumbai – 400 012 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Angpp1224L Appellant .. Respondent Appellant By : Sanjay Parikh Respondent By : Anil Sant Date Of Hearing 08.03.2024 Date Of Pronouncement 15.05.2024 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Cit(A) Nfac For A.Y. 2014-15. The Assessee Has Raised The Following Grounds Before Us: “A. Addition/Disallowance Of Short Term Capital Loss Rs.1,62,91,466/- 1. The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Cit(A)] Erred On Facts & In Law In Confirming The Addition/Disallowance Of Short Term Capital Loss Of Rs. 1,62,91,466/- As Made By The Assistant Commissioner Of Income Tax, 22(2), Mumbai (Ao). 2. While Confirming The Addition/Disallowance Of The Said Loss, The Learned Cit(A) Erred In Holding That The Appellant Had Not Made Out A Case As To How Such Huge Ltcg/Stcl Has Accrued To The Appellant From Shares Of The Company Named Global Infratech Ltd.

For Appellant: Sanjay ParikhFor Respondent: Anil Sant
Section 143(2)Section 69C

cash for the accommodation entry as at Rs.4,88,743/- being 3% of Rs.1,62,91,466/- and assesseed by the AO as unexplained expenditure u/s 69C is also upheld. Accordingly, grounds of appeal in this regard, are hereby dismissed.” 4. During the course of appellate proceedings before

Bhavika Gunwant Patel, Nagpur vs. Income Tax Officer, Ward 4(3), Nagpur

In the result, appeal filed by the assessee are allowed

ITA 366/NAG/2023[2012-13]Status: DisposedITAT Nagpur14 May 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Abhay R. Marathe
Section 10(38)Section 143(3)Section 271(1)(c)Section 69C

amounted to ` 9,430, and the same was Bhavika Gunwant Patel ITA no.366/Nag./2023 added back to the total income of the assessee as unexplained expenditure under section 69C of the Act. Subsequently, the Assessing Officer initiated penalty proceedings under section 271(1)(c) of the Act. 4. Before

Rohtang Commercial Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 331/KOL/2024[2017-18]Status: DisposedITAT Kolkata14 May 2024AY 2017-18

Bench: Shri Rajesh Kumar, Am& Shri Sonjoy Sarma, Jm]

Section 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 69

completed the assessment u/s. 144 of the Act on the basis of facts/material available before him by making two additions (i) in respect of unexplained expenditure u/s. 69 of Rs.10,94,44,200/- and (ii) unexplained cash credit u/s. 69 of the Act of Rs.13 ... made the first addition as regards unexplained expenditure by noting that assessee has investments in unlisted equity shares which is treated as unexplained investment while the addition was made in respect of unexplained expenditure. Similarly, in respect of the second addition, the AO noted that the short term loans

Khandelwal Ginning Factory, Khandwa vs. Bpl-W-(61)(94), NFAC (ITO, Ward-1), Delhi

Appeal is disposed of accordingly

ITA 474/IND/2023[2017-18]Status: HeardITAT Indore10 May 2024AY 2017-18

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

Section 147Section 253(5)Section 271A

submitted that the assessee has challenged the addition of Rs. 10,14,35,000/- made by AO in assessment-order on account of unexplained expenditure u/s 69C. But the AO has passed ex- parte assessment-order u/s 144 because of non-compliances of the notices by assessee. Similarly