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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

Khandelwal Ginning Factory, Khandwa vs. ACIT, NFAC (ITO, Ward-1, Khandwa), Delhi

Appeal is disposed of accordingly

ITA 473/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

Prakhar Dalmia, New Delhi vs. ACIT Circle-34(1), New Delhi

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

ITA 3325/DEL/2019[2014-15]Status: DisposedITAT Delhi10 May 2024AY 2014-15

Bench: Us & Prayed That Additional

Section 10(38)Section 127Section 132Section 143(2)Section 143(3)Section 153ASection 68Section 69C

facts and circumstances of the case erred in confirming the order of the Ld. AO in making addition of Rs.14,944/- as unexplained expenditure under section 69C of the Act, based on conjecture and surmises and without any evidence on record to substantiate the same.” 3. Further, assessee has filed

The DCIT, Central Circle-2, Vadodara vs. M/S. Neotech Education Foundation, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 47/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

additions sustained by the CIT(A). The quantum of sustained addition is as follows : Sr. Description of Additions Amount (Rs.) No. 1. Unexplained Expenditure u/s.69C 59,45,153/- 2. Unaccounted Cash Receipts 50,14,800/ 3. Unaccounted Money received for Shares 29,93,693/- 4. Unaccounted Receipts and Expenses ... heard both the parties and perused all the relevant material available on record. It is pertinent to note that the Tribunal in respect of unexplained expenditure under Section 69C of the Act and unaccounted cash ITA Nos.47, 108, 109 & 192/Ahd/2023 Assessment Years: 2014-15 for 4 appeals Page

The DCIT, Central Circle-2, Vadodara vs. M/S. Neotech Education Foundation, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 192/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

additions sustained by the CIT(A). The quantum of sustained addition is as follows : Sr. Description of Additions Amount (Rs.) No. 1. Unexplained Expenditure u/s.69C 59,45,153/- 2. Unaccounted Cash Receipts 50,14,800/ 3. Unaccounted Money received for Shares 29,93,693/- 4. Unaccounted Receipts and Expenses ... heard both the parties and perused all the relevant material available on record. It is pertinent to note that the Tribunal in respect of unexplained expenditure under Section 69C of the Act and unaccounted cash ITA Nos.47, 108, 109 & 192/Ahd/2023 Assessment Years: 2014-15 for 4 appeals Page

M/S. Neotech Education Foundation, Vadodara vs. The Jt.CIT, Central Range, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 109/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

additions sustained by the CIT(A). The quantum of sustained addition is as follows : Sr. Description of Additions Amount (Rs.) No. 1. Unexplained Expenditure u/s.69C 59,45,153/- 2. Unaccounted Cash Receipts 50,14,800/ 3. Unaccounted Money received for Shares 29,93,693/- 4. Unaccounted Receipts and Expenses ... heard both the parties and perused all the relevant material available on record. It is pertinent to note that the Tribunal in respect of unexplained expenditure under Section 69C of the Act and unaccounted cash ITA Nos.47, 108, 109 & 192/Ahd/2023 Assessment Years: 2014-15 for 4 appeals Page

M/S. Neotech Education Foundation, Vadodara vs. The Jt.CIT, Central Range, Vadodara

In the result, both the appeals filed by the Revenue are dismissed and both the appeals filed by the assessee are allowed

ITA 108/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad08 May 2024AY 2014-15

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2014-15

Section 260ASection 269SSection 271(1)(c)Section 271D

additions sustained by the CIT(A). The quantum of sustained addition is as follows : Sr. Description of Additions Amount (Rs.) No. 1. Unexplained Expenditure u/s.69C 59,45,153/- 2. Unaccounted Cash Receipts 50,14,800/ 3. Unaccounted Money received for Shares 29,93,693/- 4. Unaccounted Receipts and Expenses ... heard both the parties and perused all the relevant material available on record. It is pertinent to note that the Tribunal in respect of unexplained expenditure under Section 69C of the Act and unaccounted cash ITA Nos.47, 108, 109 & 192/Ahd/2023 Assessment Years: 2014-15 for 4 appeals Page

Income Tax Officer, Kalyan vs. J D Electric Works, Kalyan

In the result, the appeal of the Revenue is dismissed

ITA 4521/MUM/2023[2009-10]Status: DisposedITAT Mumbai06 May 2024AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2009-10

For Appellant: Mr. Shashank MehtaFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 1Section 148

appellant from hawala dealers. The learned AO purchases made by the appellant from hawala dealers. The learned AO has treated such entire purchases as unexplained expenditure and added has treated such entire purchases as unexplained expenditure and added has treated such entire purchases as unexplained expenditure and added to total

M/S Satwant Agro Engineers, Bhawanigarh vs. DCIT, Central Circle, Patiala

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

ITA 753/CHANDI/2022[AY 2019-20]Status: DisposedITAT Chandigarh03 May 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Deepak Anand, AdvocateFor Respondent: Shri Dharamvir, JCIT, Sr. DR
Section 115BSection 133ASection 143(2)Section 143(3)Section 68Section 69Section 69A

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

M D Diesel Spares, Howrah vs. ITO, Ward-47, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 1430/KOL/2023[2012-2013]Status: DisposedITAT Kolkata03 May 2024AY 2012-2013

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.1430/Kol/2023 Assessment Year: 2012-13 M D Diesel Spares………..………………………… ........................……Appellant 7/12, Kings Road, Howrah-711101. [Pan: Aakfm7649F] Vs. Ito, Ward-47(2), Kolkata..................…................…........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal & Saurabh Gupta, Ar, Appeared On Behalf Of The Appellant. Shri Prabir Gupta Choudhury, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 26, 2024 Date Of Pronouncing The Order : May 03, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Addition Of Rs.18,85,520/- Made By The Assessing Officer U/S 69C Of The Act On Account Of Bogus Purchases. 3. The Brief Facts Of The Case Are That The Assessee Firm Is Involved In The Business Of Spare Parts Of The Machinery. The Assessee Firm For The Year Under Consideration Filed Its Return Of Income Declaring A Total Income Of Rs.45,150/-. The Said Return Was Processed U/S 143(1) Of The

Section 143(1)Section 147Section 250Section 271(1)(c)Section 69C

agree with the aforesaid submissions and held the entire purchases as bogus and made the impugned addition of Rs.18,85,520/- as unexplained expenditure u/s 69C of the Act observing as under: “7. In response to notices the assessee submitted some documents in online. It is very much astonishing that ... Singh (Bill Mater) is treated as bogus purchase claim of the assessee and added with the returned income of the assessee on account of unexplained expenditure u/s 69C of the I.T. Act, 1961. Therefore, the said sum of Rs. 18,85,520/- is considered as undisclosed income of the assessee

DCIT, Central Circle, Kolkata vs. Merlins, Kolkata

In the result, appeal of the revenue is dismissed

ITA 907/KOL/2023[2019-20]Status: DisposedITAT Kolkata02 May 2024AY 2019-20

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 907/Kol/2023 Assessment Year: 2019-20 Deputy Commissioner Of Income Merlins Merlin House Tax, Central Circle -2(3), Kolkata Vs Samghu Nath Pandit Street Bhowanipore Kolkata - 700020 [Pan : Aatfm9627P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A.K. Tulsyan, Fca Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 06/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 02/05/2024 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) – 20, Kolkata (Hereinafter The “Ld. Cit(A)”) Dt. 02/06/2023, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2019-20. 2. The Registry Has Pointed Out That There Is A Delay Of 28 Days In Filing Of This Appeal. There Is A Petition For Condonation Of Delay Stating Therein, The Reasons For The Delay. On Perusal Of The Petition, We Are Convinced That The Revenue Was Prevented For Reasonable Cause From Filing This Appeal In Prescribed Time Limit. Accordingly, We Condone The Delay & Admit The Appeal For Hearing On Merits.

For Appellant: Shri A.K. Tulsyan, FCAFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 139(1)Section 143(2)Section 153ASection 250Section 68

case of M/s. Merlins Kolkata, also. Consequently, the disallowance for interest expenditure claimed on the alleged sum also stands deleted. Further the addition for unexplained expenditure alleged to have been incurred for arranging the accommodation entries also deserves to be deleted as the loans/capital contribution are genuine. Thus, even

Langro India Private Limited, Chennai vs. ITO, Corporate Ward 4(3), Chennai

The appeal stand allowed for statistical purposes

ITA 401/CHNY/2024[2018-19]Status: DisposedITAT Chennai01 May 2024AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.401/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2018-19) M/S Langro India Private Ltd. Ito Dugar Towers, 2Nd Floor Corporate Ward 4(3) बनाम/ Vs. 123, Marshall Road, Egmore Chennai – 600 034 Chennai – 600 008 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccl-3036-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri D.Anand (Advocate) – Ld. Ar " थ"कीओरसे/Respondent By : Shri Arv Srinivasan (Addl. Cit) – Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 29-04-2024 घोषणा की तारीख /Date Of Pronouncement : 01-05-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018- 19 Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 21-12-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 26-04-2021. In The Assessment Order, Ld. Ao Made Addition Of Unexplained Expenditure

For Appellant: Shri D.Anand (Advocate) – Ld. ARFor Respondent: Shri ARV Srinivasan (Addl. CIT) – Ld. Sr. DR
Section 143(3)

Assessing Officer [AO] u/s. 143(3) of the Act on 26-04-2021. In the assessment order, Ld. AO made addition of unexplained expenditure for Rs.40.77 Lacs on the allegation that the assessee did not disclose import purchases. The Ld. CIT(A) confirmed the same since the assessee

Lazarus Daniel Lenin Paul, Chennai vs. ITO Non Corporate Ward-10(3), Chennai

The appeal stand allowed for statistical purposes

ITA 367/CHNY/2024[2017-18]Status: DisposedITAT Chennai01 May 2024AY 2017-18

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Shri Girish Kumar (Advocate) – Ld. ARFor Respondent: Shri ARV Srinivasan (Addl. CIT) – Ld. Sr. DR
Section 143(3)

opportunity of hearing before lower authorities which has been opposed by Ld. Sr. DR. 2. In the assessment order, Ld. AO made addition of unexplained expenditure for Rs.13.88 Lacs since the assessee could not establish the source thereof. The Ld. CIT(A) confirmed the assessment since the assessee failed

Income-Tax Officer Ward 20(2)(1), Mumbai. vs. Mukhtar Ahmed Khan, Mumbai

In the result, appeal of the Revenue and the cross objection by the assessee are dismissed

ITA 3202/MUM/2023[2011-12]Status: DisposedITAT Mumbai30 Apr 2024AY 2011-12

Bench: Shri Narender Kumar Choudhry, Judicialmember & Shri Girish Agrawalassessment Year: 2011-12 Income Tax Officer, Ward-20(2)(1), Mukhtar Ahmed Khan Mumbai. 4, Kopargaon Estate, Vs. Love Lane, Mazgaon, Mumbai – 400 010 (Pan : Aacpk8056E) (Appellant) (Respondent) & C.O. No. 24/Mum/2024 In Ita No.3202/Mum/2023 Assessment Year: 2011-12

For Appellant: Shri Samir Dalal, AdvocateFor Respondent: Smt. Mahita Nair,Sr. DR
Section 143(3)Section 147

aforesaid purchases and thus held that assessee had taken accommodation entry of purchases from the said parties, thereby making an addition u/s. 69C as unexplained expenditure of Rs.89,39,268/-. 4.1. Aggrieved, the assessee went into appeal before the CIT(A). Before the ld. CIT(A), submissions were made

Sajjan Kedia HUF, Mumbai vs. Income Tax Officer Ward 30(3)(4), Mumbai

In the result, appeal is dismissed

ITA 2662/MUM/2023[2012-13]Status: DisposedITAT Mumbai30 Apr 2024AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Ratnesh Nandan Sahaymr. Sajjan Kedia Huf The Income Tax Officer, 1004,K. Palam Court, Ward 30 (3) (4), Malad Link Road, Room No.604, Malad West, C- 13, Pratyashkar Vs. Mumbai- 400064 Bhavan, Pan No. Aamhs9553G Bandra Kurla Complex, Mumbai- 400 051. (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri. Prashant Mahajan - Sr. A.R
Section 10(38)Section 143(1)Section 147Section 148Section 250Section 68Section 69C

being alleged commission paid at the rate of 5% on the alleged bogus long term capital gain as unexplained expenditure u/s. 69C of the IT Act. 8. Aggrieved by the order of assessing officer the appellant filed appeal before the Ld. CIT Appeal. However, the appellant did not pursue

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1749/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Apr 2024AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

group including the assessee. Thereafter the learned assessing officer held that there is an addition under section 69C of the act being unexplained expenditure on account of commission paid on accommodation entries of sales and purchases is taxable in the hands of the assessee. The learned assessing officer noted that ... 17/10/2016 of ₹ 7,80,22,797/–. Thus, the addition of ₹ 712,745,262/– is the addition under section 69C of the act as an unexplained expenditure on account of commission paid on accommodation entries of sales and purchases of the assessee at the rate of 3% was also made taxable

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1748/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Apr 2024AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

group including the assessee. Thereafter the learned assessing officer held that there is an addition under section 69C of the act being unexplained expenditure on account of commission paid on accommodation entries of sales and purchases is taxable in the hands of the assessee. The learned assessing officer noted that ... 17/10/2016 of ₹ 7,80,22,797/–. Thus, the addition of ₹ 712,745,262/– is the addition under section 69C of the act as an unexplained expenditure on account of commission paid on accommodation entries of sales and purchases of the assessee at the rate of 3% was also made taxable

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1747/MUM/2022[2014-15]Status: DisposedITAT Mumbai30 Apr 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

group including the assessee. Thereafter the learned assessing officer held that there is an addition under section 69C of the act being unexplained expenditure on account of commission paid on accommodation entries of sales and purchases is taxable in the hands of the assessee. The learned assessing officer noted that ... 17/10/2016 of ₹ 7,80,22,797/–. Thus, the addition of ₹ 712,745,262/– is the addition under section 69C of the act as an unexplained expenditure on account of commission paid on accommodation entries of sales and purchases of the assessee at the rate of 3% was also made taxable

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1746/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Apr 2024AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

group including the assessee. Thereafter the learned assessing officer held that there is an addition under section 69C of the act being unexplained expenditure on account of commission paid on accommodation entries of sales and purchases is taxable in the hands of the assessee. The learned assessing officer noted that ... 17/10/2016 of ₹ 7,80,22,797/–. Thus, the addition of 712,745,262/– is the addition under section 69C of the act as an unexplained expenditure on account of commission paid on accommodation entries of sales and purchases of the assessee at the rate of 3% was also made taxable

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Shrivallab Pitte Industries Ltd, Mumbai

ITA 1745/MUM/2022[2015-16]Status: DisposedITAT Mumbai30 Apr 2024AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

group including the assessee. Thereafter the learned assessing officer held that there is an addition under section 69C of the act being unexplained expenditure on account of commission paid on accommodation entries of sales and purchases is taxable in the hands of the assessee. The learned assessing officer noted that ... 17/10/2016 of ₹ 7,80,22,797/–. Thus, the addition of 712,745,262/– is the addition under section 69C of the act as an unexplained expenditure on account of commission paid on accommodation entries of sales and purchases of the assessee at the rate of 3% was also made taxable

Asstt Commissioner of Income Tax, Central Circle-6(1), Mumbai vs. Helios Mercantile Limited, Mumbai

ITA 1744/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Apr 2024AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

group including the assessee. Thereafter the learned assessing officer held that there is an addition under section 69C of the act being unexplained expenditure on account of commission paid on accommodation entries of sales and purchases is taxable in the hands of the assessee. The learned assessing officer noted that ... 17/10/2016 of ₹ 7,80,22,797/–. Thus, the addition of 712,745,262/– is the addition under section 69C of the act as an unexplained expenditure on account of commission paid on accommodation entries of sales and purchases of the assessee at the rate of 3% was also made taxable