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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

Our Vision Entertainment LLP, Mumbai vs. Assistant Commissioner of Income Tax Circle 24(1), Mumbai

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

ITA 4724/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Ms. Renu Jauhriassessment Year: 2016-17 M/S. Our Vision Entertainment Income Tax Officer Llp, 15(1)(1), Office No.304, Twin Complex B 103, Aayakar Bhavan, Vs. Block, Andheri East Mumbai - 400020 Opp Marol Fire Brigade Maharashtra - 400 059 Pan: Aaefo8646C (Appellant) (Respondent)

Section 144Section 250

additions of Rs. 1,14,62,761/- and Rs. 6993/- respectively on account of unexplained cash credit u/s 68 of the Act and unexplained expenditure, as ex-parte on non-prosecution by the Assessee and without condoning the delay of 99 days in filing 1st appeal, however proceeded further with

Rak Magnum Realty LLP, Mumbai vs. Income Tax Officer-20(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 4411/MUM/2024[2012-13]Status: DisposedITAT Mumbai02 Dec 2025AY 2012-13

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(3)Section 147Section 148Section 153CSection 68Section 69C

invoked the provisions of section 69C of the Act and made an addition of ₹1,03,78,740/- treating the impugned transaction as unexplained expenditure. Aggrieved by the order of the Ld. AO, assessee preferred appeal before the Ld. CIT(A). 3. Before the Ld. CIT(A) the assessee contended

T R Chemicals Limited, Odisha vs. PCIT Sambalpur, Odisha

In the result, appeal of the assessee is allowed

ITA 219/CTK/2025[2018-19]Status: DisposedITAT Cuttack01 Dec 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.219/Ctk/2025 (िनधा"रण वष" / Assessment Year : 2018-2019) T R Chemicals Limited, Vs Pr.Cit, Sambalpur Main Road, Subash Chowk, Rajgangpur, Odisha-770017 Pan No. :Aabct 1919 M (अपीलाथ" /Appellant) .. (""थ" / Respondent) िनधा"रती की ओर से /Assessee By : Shri K.K.Bajoria & Shri Yogesh Banka, Ars राज" की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/12/2025 घोषणा की तारीख/Date Of Pronouncement : 01/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Pr.Cit, Sambalpur, Dated 15.01.2025 For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld. Ar That The Return Filed By The Assessee Came To Be Processed & The Assessment Came To Be Completed U/S.147 Of The Act Wherein The Purchases From M/S Mideast Integrated Steel Ltd. Were Disallowed By Invoking The Provisions Of Section 37(1) Of The Act. It Was The Submission That The Ld. Pr.Cit Invoked His Power U/S.263 Of The Act On The Ground That The Disallowances Made By The Ao U/S.37(1) Of The Act Instead Of Section 69C Of The Act, Is Erroneous & Prejudicial To The Interest Of Revenue. It Was Submitted That The Issue Is Now Squarely Covered By The Decision Of The Coordinate Bench Of The Tribunal In The Case Of Bajrang Steel & Alloys (P) Ltd., Passed In Ita No.553/Ctk/2024, Order Dated

For Appellant: Shri K.K.Bajoria & Shri Yogesh Banka, ARsFor Respondent: Shri Vijay Singh, Sr. DR
Section 147Section 263Section 37(1)Section 69C

with M/s Mideast Integrated Steel Ltd. A perusal of the provisions of Section 69C of the Act shows that it is in respect of unexplained expenditure. It is a case where the assessee offered no explanation about the source(source) of such expenditure or part thereof. The case before

Prakash Chand, Shimla vs. Income Tax Officer, Shimla

The appeal stand allowed

ITA 1215/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh01 Dec 2025AY 2018-19

Bench: us.3. The Ld. AR has placed on record computation of agricultural income. It could be seen that the assessee has earned gross agricultural income of Rs.86.01 Lacs and incurred various expenditure on account of labor charges, salary, packing charges, fertilizers & chemicals and finally, computed agricultural income of Rs.47.30 Lacs. The transaction-wise detail along with source of payment has also been furnished. In its reply to Ld. CIT(A) on 04-09-2024, the assessee had furnished details of

For Appellant: Sh. Vishal Mohan (Sr. Advocate) with Sh. PraveenFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(3)Section 69C

Accordingly, the agricultural expenditure of Rs.38.70 Lacs as claimed by the assessee was held to be non-genuine and the same was added as unexplained expenditure u/s 69C. The assessee filed first appeal wherein the addition was confirmed against which the assessee is in further appeal before ... Nevertheless, when all the expenditure has been routed through known sources of income, the same could not be held to be unexplained expenditure. The provisions of Sec.69C have no applicability to the facts of the present case since the only allegation of Ld. AO was that the expenditure

Renu Anandani, Jabalpur vs. NFAC, Delhi

In the result, the appeal is allowed for statistical purposes

ITA 120/JAB/2023[2012-13]Status: DisposedITAT Jabalpur28 Nov 2025AY 2012-13

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Neeraj Agarwal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(3)Section 147Section 263

disallowed the claim of short term capital loss of Rs. 21,72,628/- and also added Rs. 43,452/- as unexplained expenditure and passed an order under section 147 of the Income Tax Act on 30.12.2019. The assessee had opted for the VSVS and paid the tax thereon. Subsequently

Kallidumbil Nechithadathi Shajahan, Malappuram vs. ITO, Ward-2, Tirur

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

ITA 862/COCH/2025[2019-20]Status: DisposedITAT Cochin28 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Kallidumbil Nechithadathi Shajahan .......... Appellant Nechithadathil, Puthyr, Pallikkal Devathiyal, Malappuram 673636 [Pan: Jcbps9648E] Vs. The Income Tax Officer, Ward-2, Tirur .......... Respondent Assessee By: Shri Raghunathan, Advocate Revenue By: Ms. Neethu S. Sr. Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 29.09.2025 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Engaged In The Business Of Wholesale Trade Of Dry Fruits, Chocolates, Etc. No Regular Return Of Income For Ay 2019-20 Was Filed By The Appellant. However, Based On The Information That The Appellant Had Made Imports Aggregating To Rs. 30,23,148/- The Ao Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, Issued A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) On 2 Kallidumbil Nechithadathi Shajahan 05.04.2023 After Complying With The Procedures Laid Down Ups 148A Of The Act. The Appellant Neither Complied With The Notice U/S. 148 Nor Filed The Information Sought For By The Ao. In The Circumstances The Ao Made Addition Of Rs. 38,75,086/- Treating The Entire Imports As Unexplained Expenditure Of The Appellant.

For Appellant: Shri Raghunathan, AdvocateFor Respondent: Ms. Neethu S. Sr. DR
Section 148

information sought for by the AO. In the circumstances the AO made addition of Rs. 38,75,086/- treating the entire imports as unexplained expenditure of the appellant. 3. Being aggrieved, an appeal was filed before the CIT(A) with a delay of 118 days. The CIT(A) had dismissed

Rajveer Leaf Springs Private Limited, Palda. Indore vs. DCIT/ACIT- 4(1), Aayakar Bhawan, Residency Area, Indore

The appeal of the assesse is allowed for statistical purpose

ITA 245/IND/2025[2018-19]Status: DisposedITAT Indore28 Nov 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M Joshirajveer Leaf Springs Dcit/Acit-4(1), बनाम/ Private Limited, Indore Vs. D-405, Shubh City, Palda, Indore

Section 133(6)Section 147rSection 246ASection 250Section 253Section 69C

under Section 69C of the Income Tax Act, 1961, Page 3 of 10 Rajveer Leaf Springs Private Limited ITA No.245/Ind/2025 - A.Y. 2018-19 as unexplained expenditure, is erroneous and unjustified. The assessee contends that the AO erred in passing the order by invoking Section 69C of the Income ... validate the AO's approach to disallowing the full amount of purchases from the flagged entities. 5.3.6 Section 69C allows the AC to treat unexplained expenditure as income if the assessee fails to substantiate it with evidence. In this case, the purchases of Rs. 4.62.63,870 lacked any credible documentation

Nilesh Jayantilal Shah, Ahmedabad vs. NFAC, Delhi, Juridis. AO- the ITO, Ward-2(1)(2), Ahmedabad

The appeals of the assessee are allowed for

ITA 908/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 115BSection 144Section 147Section 148Section 234ASection 271(1)(c)Section 69Section 69ASection 69C

account as unexplained money under Section 69 of the Act. Further, the entire debit transaction of Rs.3,21,38,779/- was also treated as unexplained expenditure under Section 69C of the Act. The assessment was completed under section 147 read with Section 144 of the Act dated

Nilesh Jayantilal Shah, Ahmedabad vs. NFAC, Delhi, Juridis. AO- the ITO, Ward-2(1)(2), Ahmedabad

The appeals of the assessee are allowed for

ITA 907/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 115BSection 144Section 147Section 148Section 234ASection 271(1)(c)Section 69Section 69ASection 69C

account as unexplained money under Section 69 of the Act. Further, the entire debit transaction of Rs.3,21,38,779/- was also treated as unexplained expenditure under Section 69C of the Act. The assessment was completed under section 147 read with Section 144 of the Act dated

Jitendra Rajkumar Agarwal (Proprietor of Shri Shiv Shakti Enterprise), Ahmedabad vs. Asessment Unit, It Department Juris. AO- the ITO, Ward-3(3)(2), Ahmedabad

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

ITA 1718/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Sanjay R Shah, CAFor Respondent: Shri Abhijit, Sr. DR
Section 115BSection 133(6)Section 144BSection 147Section 148Section 69C

assessee engineered bogus purchases merely to inflate expenses and reduce taxable profit. The entire purchases of Rs. 1,75,16,480/- were treated as unexplained expenditure under section 69C and taxed under section 115BBE. The assessment was completed under section 147 read with section 144B determining total income ... disallowance of genuine purchase made by the Appellant from M/s. S.K. Enterprise for a sum of Rs.1,75,16,480/- and treating them as unexplained expenditure u/s.69C of the Act. It is submitted that the addition as confirmed by the learned CIT(Appeals) deserves to be deleted and the same

Orange City Recreation Resort Pvt Ltd, Mumbai vs. Income Tax Officer, WD-7(3)(1), Mumbai

In the result, the Assessee’s appeal is allowed

ITA 5698/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Nov 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Prakash JhunjhunwalaFor Respondent: Shri Rajendra Joshi (Sr. DR)
Section 250Section 68Section 69C

being 0.25% of Rs. 40,00,000/- as commission paid to Mr. Rajesh Bhutoria for the services availed, as unexplained expenditure u/s. 69C of the Act. 5. The assessee challenged the said additions by filing first appeal before the Ld. Commissioner, who not only affirmed the addition on legal aspect

Income Tax Officer 19.1.1, Piramal Chamber Lal Baug vs. A J Diam, Mumbai

In the result, appeal filed by the revenue is dismissed in the above terms

ITA 3845/MUM/2025[2011-12]Status: DisposedITAT Mumbai28 Nov 2025AY 2011-12

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhanito-19(1)(1), Mumbai A. J. Diam Room No. 501, Piramal Chamber, Vs. 304, 3Rd Floor, Deccan Vikas Chs Lalbaug, Mumbai-400 012. Ltd. 584/1/584, Vithalbhai Patel Road, Kothachiwadi, Mumbai- 400 004 Pan: Aaofa4830G (Appellant) (Respondent)

Section 143(3)Section 148Section 250Section 271(1)(c)Section 274

allowed, by rejecting the Hon'ble ITAT decision of estimating the profit rate @ 12.5% on bogus purchases and thereby impliedly grant deduction of such unexplained expenditure incurred u/s 69C of the Act, even though, the assessee failed to discharge its onus to prove genuineness of alleged purchases and has offered

Sandeep Kumar, New Delhi vs. ITO - Ward 1, Panipat

In the result, appeal of the assessee is allowed

ITA 4348/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Sandeep Kumar, Vs Ito C/O-B-50, Lgf, South Ward-1 Extension Part-Ii, Panipat New Delhi -110049 Pan-Aueps5626A Appellant Respondent Appellant By Shri Shantanu Jain, Adv. Ms. Jahnavi Khanna, Adv. Shri Gurjeet Singh, Ca Respondent By Shri Khitesh Gupta, Sr.Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 28.11.2025 Order

Section 147Section 148Section 250Section 263Section 69C

orders of Ld. PCIT and submit that in the instant case, the assessee has failed to justify the purchases made thus the same is unexplained expenditure for which the source was not established to the satisfaction of the AO and therefore, Ld. Pr. CIT has rightly direct ... income of the assessee by such for such financial year. Provided that notwithstanding anything standing contained in any other provision of this Act such unexplained expenditure which deemed to be he income of the assessee shut not be allowed as a deduction under any head of income. 13. The provisions

Shri Rakesh Arora, Delhi vs. ITO Ward-30(8), Delhi

In the result, Ground no. 3 as raised by the assessee deserves to be allowed and the impugned addition cannot be sustained

ITA 2159/DEL/2025[2012-13]Status: DisposedITAT Delhi28 Nov 2025AY 2012-13

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2012-13] Sh. Rakesh Arora Ito C-4, 4123 Ward- 30 (8) Vasant Kunj, Vs Delhi Delhi-110070 Pan No.Aaepa727P Appellant Respondent Appellant By Sh. Lalit Mohan, Ca Respondent By Sh. Ajay Kumar Arora, Sr. Dr Date Of Hearing 23.09.2025 Date Of Pronouncement 28.11.2025

Section 147Section 148Section 69Section 69A

cheque) as unexplained cash credit under Section 68 of the Act; and, iii) Rs.20,62,375/-under Section 69 of the Act being unexplained expenditure as assessee was found to have purchased property for the said sum. It appears that during the assessment proceedings, the Assessing Officer had called upon ... additions Rs.15,40,000/- under Section 68 of the Act on account of deposit of cash/cheques which went unexplained and Rs.20,62,375/- being unexplained expenditure on purchase of property under Section 69 of the Act. The learned CIT(A) has deleted the addition on account of the alleged bogus

Abhishek Agarwal, Delhi vs. Assisstant Commissioner of Income Tax, Central Circle 28, Delhi

In the result, the appeal of the assessee is allowed

ITA 1133/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2014-15] Abhishek Agarwal, Acit 9/49, West Punjabi Bagh Central Circle -28 Delhi Vs Delhi Pan No.Ajjpa3173G Appellant Respondent Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Advocate Revenue By Sh. Amit Jain, Cit Dr Date Of Hearing 23.09.2025 Date Of Pronouncement 28.11.2025

Section 143(2)Section 153CSection 153DSection 69ASection 69C

erred both on facts and in law in confirming an addition of Rs. 90,000/- under section 69C of the Act as unexplained expenditure on account of commission at the rate of 3% paid on the above transactions from the alleged undisclosed sources. (ii) That the aforesaid addition has been

Rahool N Kanal, Mumbai vs. ACIT Central Circle 5(4), Mumbai

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

ITA 5713/MUM/2025[2020-21]Status: DisposedITAT Mumbai27 Nov 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry, Jm Rahool N Kanal Acit, Central Circle 5(4), Flat No. 201, 9 Almeida Mumbai Behind Bhabha Hospital, Vs. Bandra West, Mumbai – 400050. Pan/Gir No. Bjspk5163Q (Appellant) : (Respondent) Assessee By : Shri Mohan Tandon Respondent By : Shri Saurabh Raskar, Sr. Dr (Virtually Present) Date Of Hearing : 20.11.2025 Date Of Pronouncement : 27.11.2025

For Appellant: Shri Mohan TandonFor Respondent: Shri Saurabh Raskar, SR. DR
Section 250Section 69C

Rahool N Kanal 2. In the instant case, the Assessing Officer (AO) made the addition of Rs. 4,00,000/- on account of unexplained expenditure incurred u/s. 69C of the Act being expenditure of Rs. 2,00,000/- per foreign trip from Mumbaii. It appears from the assessment order that

Dy. Commissioner of Income Tax, Noida vs. M/S Ace Mega Structure Private Limited, Noida

In the result, appeal of the assessee is allowed

ITA 4115/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

applicable to the facts of the case. The basis of the addition pertains to alleged unexplained investment, whereas Section 69C specifically applies to unexplained expenditure. Therefore, the invocation of Section 69C is erroneous and unsustainable in law.” 10. Ground of appeal No.3 raised by the assessee is with respect ... observed that these properties were purchased by the assessee below the circle rate and therefore, has made the payment of the said cash as unexplained expenditure u/s 69C r.w.s. 115BBE of the Act. 14. Ld. AR further submits that in first appeal, before Ld. CIT(A), it was claimed

Ace Mega Structures Private Limited, Uttar Pradesh vs. DCIT/ACIT Cen Cir, Noida

In the result, appeal of the assessee is allowed

ITA 4067/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

applicable to the facts of the case. The basis of the addition pertains to alleged unexplained investment, whereas Section 69C specifically applies to unexplained expenditure. Therefore, the invocation of Section 69C is erroneous and unsustainable in law.” 10. Ground of appeal No.3 raised by the assessee is with respect ... observed that these properties were purchased by the assessee below the circle rate and therefore, has made the payment of the said cash as unexplained expenditure u/s 69C r.w.s. 115BBE of the Act. 14. Ld. AR further submits that in first appeal, before Ld. CIT(A), it was claimed

Joginder Kumar & Sons HUF, Panipat vs. PCIT Rotak, Rotak

In the result, the appeal of the assessee is allowed

ITA 1975/DEL/2025[2018-19]Status: DisposedITAT Delhi27 Nov 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwaljoginder Kumar & Sons Huf Pcit, 352/6, Near S D Modern School, Rohtak. Panipat-132103. Vs. Pan- Aachj6257L (Appellant) (Respondent) Assessee By Shri Dhurv Goel, Ca Department By Shri Pradumna Kumar Singh, Sr. Dr Date Of Hearing 04.09.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Rohtak (‘The Pcit’ In Short) Passed U/S 263 Of The Income Tax Act, 1961 Dated 21.03.2025 Wherein The Ld. Pcit Held The Assessment Order As Erroneous & Prejudicial To The Interest Of The Revenue In Terms Of Explanation 2 Of Section 263 & Direct The Ao To Conduct Fresh Enquiries & Passed The Speaking Order.

Section 115BSection 147Section 148Section 263Section 37(1)Section 69C

income of the assessee by such for such financial year. Provided that notwithstanding anything standing contained in any other provision of this Act such unexplained expenditure which deemed to be he income of the assessee shut not be allowed as a deduction under any head of income. (iii) Further

Rakesh Kumar, Kanpur vs. Deputy Commissioner of Income Tax, Agra

In the result, ITA Nos. 431, 437 & 432/Agr/2024 filed by the revenue

ITA 449/AGR/2024[2021-22]Status: DisposedITAT Agra26 Nov 2025AY 2021-22

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 127Section 132(1)Section 142(1)Section 148Section 250(6)

with the explanation tendered by assessee during the assessment proceedings and added Rs.84,32,000/- as said cash loan and Rs.10,00,000/- as unexplained expenditure u/s. 69C of the Act in the income of the assessee. 4. Aggrieved, assessee preferred first appeal before ld. CIT(Appeals), who deleted both