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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

Merchandisers (P) Ltd, Mattancherry vs. DCIT.Corporate Circle-2(1), Kochi

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

ITA 601/COCH/2025[2016-17]Status: DisposedITAT Cochin29 Oct 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Merchandisers (P) Ltd. .......... Appellant 7/594, Jew Town, Mattancheery, Kochi [Pan: Aabcm6455D] Vs. Dcit, Corporate Circle-2(1), Kochi ......... Respondent Assessee By: Shri Thomson Thomas, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 06.08.2025 For Assessment Year (Ay) 2016-17. 2. Brief Facts Of The Case Are That The Appellant Is A Private Limited Company Engaged In The Business Of Trading In Raw-Rubber. The Return Of Income For Ay 2016-17 Was Filed On 17.10.2016 Disclosing Loss Of Rs. 3,79,128/-. The Said Return Of Income Was Processed U/S. 143(1) Of The Income Tax Act, 1961 (The Act) Accepting The Returned

For Appellant: Shri Thomson Thomas, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(1)Section 147Section 148Section 153B

vide order dated 03.05.2023 passed u/s. 147 r.w.s. 144B of the Act after making addition of Rs. 1,45,91,304/- as unexplained expenditure of the appellant and applied the tax rate as prescribed u/s. 153BBE of the Act. 3. Being aggrieved, an appeal was filed before

ACIT, Anand Circle, Anand vs. Narendrakumar Hansrajbhai Patel, Kheda

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

ITA 834/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.834/Ahd/2024 िनधा"रण वष" /Assessment Year : 2021-22 The Acit Narendrakumar Hansrajbhai बनाम/ Dy./Asst.Commissioner Of Patel V/S. Income Tax (Anand Circle) I C/O. Mahakali Saw Mill Anand – 388 001 Mansarovar Marker Kamla Kamia, Kheda – 387 320 "थायी लेखा सं./Pan: Cmmpp 6784 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mishal Mehta, Ca Revenue By : Shri Alpesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/08/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/02/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2021-2022. 2. The Revenue Has Raised The Following Grounds Of Appeal: “1. Whether, On Facts & In Circumstances Of The Case & In Law, The Ld.Cit(A) Is Justified In Deleting The Addition Of Rs. 10,64,04,151/-Made U/S 69C Of The Act Without Appreciating The Fact The Assessee Failed To Substantiate The Expenditure Claimed With Supporting Evidences? Asst.Cit Vs. Narendrakumar Hansrajbhai Patel Asst. Year : 2021-22

For Appellant: Shri Mishal Mehta, CAFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 133(6)Section 143(3)Section 250Section 69C

that certain suppliers’ GST numbers were cancelled and some were non- filers. On this basis, the AO treated the said purchases as unexplained expenditure under section 69C of the Act and added ₹10,64,04,151/- to the total income of the assessee, completing the assessment under section

DCIT-42(1)(1), Mumbai vs. Sri Uday Ghanshyam Naik, Mumbai

In the result, the cross

ITA 989/MUM/2025[2018]Status: DisposedITAT Mumbai29 Oct 2025

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19

For Appellant: Ms. Kavita P. Kaushik, Sr. DR
Section 68

ADDITION OF RS.20,000/ (4) ADDITION OF RS.20,000/- OUT OF ORIGINAL ADDITION OF OUT OF ORIGINAL ADDITION OF 8,42,94,769/7 AS UNEXPLAINED EXPENDITURE U/S. 69C 42,94,769/7 AS UNEXPLAINED EXPENDITURE U/S. 69C – 42,94,769/7 AS UNEXPLAINED EXPENDITURE U/S. 69C (4.1) On the facts and circumstances ... having earned earned agricultural agricultural income. income. The The agricultural agri cultural expenses expenses of of ₹12,09,809/– were also disallowed as unexplained expenditure were also disallowed as unexplained expenditure were also disallowed as unexplained expenditure under Section 69C. Accordingly, the total income of the assessee under Section

Income Tax Officer 19(1)(1), Mumbai vs. Badamidevi Tejraj Mutha, Mumbai

In the result, the appeal of the Revenue is allowed for

ITA 2269/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Oct 2025AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Respondent: None
Section 133Section 37Section 68Section 69CSection 74

been allowed, by rejecting the ITAT's 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 the genuniness of alleged purchases and has offered

Uday Ghanshyam Naik, Mumbai vs. ITO Circle 42(1)(1), Mumbai

In the result, the cross

ITA 1098/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Oct 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19

For Appellant: Ms. Kavita P. Kaushik, Sr. DR
Section 68

ADDITION OF RS.20,000/ (4) ADDITION OF RS.20,000/- OUT OF ORIGINAL ADDITION OF OUT OF ORIGINAL ADDITION OF 8,42,94,769/7 AS UNEXPLAINED EXPENDITURE U/S. 69C 42,94,769/7 AS UNEXPLAINED EXPENDITURE U/S. 69C – 42,94,769/7 AS UNEXPLAINED EXPENDITURE U/S. 69C (4.1) On the facts and circumstances ... having earned earned agricultural agricultural income. income. The The agricultural agri cultural expenses expenses of of ₹12,09,809/– were also disallowed as unexplained expenditure were also disallowed as unexplained expenditure were also disallowed as unexplained expenditure under Section 69C. Accordingly, the total income of the assessee under Section

ACIT 4(3)(1), Mumbai vs. Narayan Dalpatram Thakkar, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3619/MUM/2017[2008-09]Status: DisposedITAT Mumbai29 Oct 2025AY 2008-09

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2008-09 Assistant Commissioner Of Vs Narayan Dalpatram Income-Tax - 4(3)(1), Thakkar Mumbai Abhay Bldg, 5Th Floor, Ns 9Th Rdm Jvpd Scheme, Juhu Vile Parle (W), Mumbai - 400032 [Pan: Aaipt0713F] Appellant Respondent Present For: Assessee : Shri Parag Shah, Ca Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 05.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Cit(A) – 9, Mumbai, Vide Order No. Cit(A)-9/Cir.4/529/2015-16, Dated 17.03.2016 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax-4(3)(1), U/S.143(3) R.W.S. 147 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 29.01.2016 For Ay 2008-09. 2. Grounds Taken By The Revenue Are Reproduced As Under: “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Directing The Ao To Delete The Addition Made Towards Unexplained Unsecured Loan Of Rs.65,00,000/- U/S.68 Of The I.T. Act.

For Appellant: Shri Parag Shah, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Section 143(3)Section 148Section 68Section 69C

after making an addition of Rs.65 lakhs as unexplained cash credit u/s. 68 and of Rs. 87,547/- as unexplained expenditure on account of interest on unsecured loans by applying provisions of section 69C. These additions were based on information from the Directorate General of Income Tax Investigation, Mumbai indicating

Ishan Arora, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 669/JPR/2025[2008-09]Status: DisposedITAT Jaipur28 Oct 2025AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Yogesh Sharma, AdvFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT a
Section 139Section 142(1)Section 144Section 148Section 154Section 234ASection 250Section 44ASection 69C

from regular cash sales, supported by VAT returns and invoices. 4. That the Ld. AO erred in treating Rs. 2,84,255 as unexplained expenditure u/s 69C, ignoring that it related to credit card payments for business purchases and household expenses (drawings). 5. That the assessment framed u/s 144/147 ... dated 23.12.2013, therefore, ld. AO hold that payment of credit card bills 4 Ishan Arora vs. ITO amounting to Rs. 2,84,255/- as unexplained expenditure u/s 69C of the Act and added to the total income of the assessee. 4. Aggrieved from the order

Kishan Lal Meena, Jaipur vs. ITO WD 1(3), Jaipur

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

ITA 1155/JPR/2025[2009-10]Status: DisposedITAT Jaipur28 Oct 2025AY 2009-10
For Appellant: Shri Anoop Bhatia, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 69ASection 69C

burden of proof cast u/s 69C of the Act. Thus the Id. CIT(A) upheld the addition u/s 69C of the Act as unexplained expenditure as made by the AO in the assessment order. The narration so made by the Id. CIT(A) in his order at para ... para 12 are reproduced as under:- "8.8 In the present case it is soon the assessee was found to have made unexplained expenditure by way of credit card payments amounting to Rs 15,75,677/-that no explanation was provided by the assessee during the assessment proceedings in spite

M/S Vxa Global LLP, Jaipur vs. Income Tax Officer, Ward 1(1), Jaipur

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

ITA 1027/JPR/2025[2021-22]Status: DisposedITAT Jaipur28 Oct 2025AY 2021-22

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Ms. Paridhi Jain, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 144Section 144BSection 250Section 37(1)

arbitrary and illegal in making addition of a sum of Rs 1,33,17,500.00 treating purchases as bogus purchases and treating it as unexplained expenditure under section 37(1). 8) The Learned NFAC (Appeals) has erred in law and on facts in upholding the Order of AO in which ... arbitrary and illegal in of Rs 37,44,000.00 disallowing the ITC and treating it as bogus purchases and making it as unexplained expenditure under section 37(1) and adding the same as income 9) The Learned NFAC (Appeals) has erred in law and on facts in upholding the Order

Dar E Imaan Welfare and Educational Trust, Vellore vs. ITO, Exemption Ward, Chennai

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

ITA 2259/CHNY/2025[2019-20]Status: DisposedITAT Chennai28 Oct 2025AY 2019-20

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2259/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 Dar E Imaan Welfare & Educational Vs. The Income Tax Officer, Trust, No. 434/1, G. Kayide Millath Exemption Ward, Nagar, Kathiyavadi, Melvisharam, Chennai. Vellore 632 509. [Pan: Aactd2327B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri C.P. Solomon, Jcit सुनवाई की तारीख/ Date Of Hearing : 22.10.2025 घोषणा की तारीख /Date Of Pronouncement : 28.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2019-20. 2. When The Appeal Was Taken Up For Hearing, None Appeared On Behalf Of The Assessee Nor Filed Any Adjournment Petition. Hence We

For Appellant: NoneFor Respondent: Shri C.P. Solomon, JCIT
Section 69C

consideration as to whether the ld. CIT(A) is justified in confirming the disallowance of claim of deduction and treating the same as unexplained expenditure under section 69C of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances of the case. 4. It is noted that ... Assessing Officer added an amount of Rs.2,23,149/- under section 69C of the Act on account of unexplained expenditure in the absence of any evidence to that effect which is clear from paras 1 and 2 of the assessment order. In the first appellate proceedings

DCIT-CC-6(1), Mumbai, Bkc, Kautilya Bhawan vs. Prashant Prakash Nilawar, Pune

In the result, the appeal of the Revenue, being ITA

ITA 2896/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Appellant: 1.1. On the facts and circumstances of the case and in law
Section 69ASection 69BSection 69C

evidence found suggesting that any such alleged unaccounted expenses were incurred by the assessee. Hence, the addition made of Rs. 11,20,000/- as unexplained expenditure u/s 69C of the Act is liable to be deleted. 2. Addition of unexplained cash-on-hand ... against the returned income of ₹3,87,39,970/-. The additions made by the Assessing Officer may be summarised thus: Sr.No. Particulars Amount 1 Unexplained expenditure u/s69C as per para7 of 5,35,15,187/- the assessment order 2 Unexplained expenditure u/s 69C as per para

Prashant Prakash Nilawar, Pune vs. ACIT Circle-6(1), Nariman Point Mumbai

In the result, the appeal of the Revenue, being ITA

ITA 2318/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23
For Appellant: 1.1. On the facts and circumstances of the case and in law
Section 69ASection 69BSection 69C

evidence found suggesting that any such alleged unaccounted expenses were incurred by the assessee. Hence, the addition made of Rs. 11,20,000/- as unexplained expenditure u/s 69C of the Act is liable to be deleted. 2. Addition of unexplained cash-on-hand ... against the returned income of ₹3,87,39,970/-. The additions made by the Assessing Officer may be summarised thus: Sr.No. Particulars Amount 1 Unexplained expenditure u/s69C as per para7 of 5,35,15,187/- the assessment order 2 Unexplained expenditure u/s 69C as per para

Rajesh Narendra Mewawalla, Mumbai vs. DCIT Central Circle 3(3), Mumbai

ITA 1567/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17

Bench: Shri Beena Pillai & Smt.Renu Jauhrirajesh Narendra Vs. Dcit Central Circle 3(3) Mewawalla Room No. 1923, Air India Flat No. 2, 1St Floor, Building, Nariman Point, Nutan Prakash Building No. Mumbai-400021. 2, Walkeshwar, Mumbai-400006. "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aabpm8200H Appellant .. Respondent

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Annavaran Kosuri- Sr. AR
Section 148Section 151(2)Section 250Section 288ASection 69ASection 69C

determining the total income as under: Salary Rs. 9,60,000/- Add: Unexplained cash credit u/s. 69A Rs. 241,92,400/- Add. Unexplained expenditure u/s. 69C Rs. 61,74,465/- Total Assessed Income Rs. 3,13,26,865/- Rounded off u/s. 288A Rs. 3,13,26,870/- 4.2 Aggrieved with

Rajesh Kumar Morodia, New Delhi vs. Office of the Income Tax Officer, Ward 53(2), Delhi, New Delhi

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 5457/DEL/2025[2017-18]Status: HeardITAT Delhi28 Oct 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Rajesh Kumar Morodia, Vs. Ito, Ward 53(2), H.No. 1539, Gali Number 5, Delhi. Wazir Nagar, Kotla Mubarakpur, New Delhi. (Pan: Aphpm3594B) (Appellant) (Respondent) Appellant By : Shri Vijay Kumar Gupta, Ca Respondent By : Shri Manoj Kumar, Sr. Dr

For Appellant: Shri Vijay Kumar Gupta, CAFor Respondent: Shri Manoj Kumar, Sr. DR
Section 115Section 69C

which comes to Rs. 10,59,900/- was added to the income of the assessee by the AO u/s. 69C of the Act as unexplained expenditure. Aggrieved, assessee appealed before the Ld. CIT(A), who vide order dated 20.8.2025 has upheld the addition. Against the aforesaid, assessee is in appeal

ACIT, Delhi vs. Sri Prem Properties Private Limited, New Delhi

Appeal is dismissed

ITA 4169/DEL/2025[2010-11]Status: DisposedITAT Delhi28 Oct 2025AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2010-11 Vs. Sri Prem Properties Private Acit, Delhi Ltd., D-6/6032/2, Vasant Kunj, New Delhi Pan: Aaacs2554E (Appellant) (Respondent) Assessee By Sh. Deepesh Garg, Adv. Department By Sh. Mahesh Kumar, Cit(Dr)

Section 132Section 139Section 142(1)Section 143(2)Section 153Section 153ASection 153CSection 250Section 69C

without considering the merit of the case, the details of the additions made by the Assessing Officer are as under: (i) On account of unexplained expenditure u/s 69C of the Act to the tune of Rs.3,00,00,000/-. 2. Whether on the facts and circumstances of the case

Assistant Commissioner of Income Tax, Jalgaon vs. Sidharth Ratanlal Bafna, Jalgaon

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1565/PUN/2024[2018-19]Status: DisposedITAT Pune27 Oct 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: S/Shri Suchek Anchaliya andFor Respondent: Shri Amit Bobde, CIT
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Assistant Commissioner of Income Tax, Jalgaon vs. Sidharth Ratanlal Bafna, Jalgaon

In the result, all the above 6 appeals filed by the Revenue are dismissed and

ITA 1555/PUN/2024[2013-14]Status: DisposedITAT Pune27 Oct 2025AY 2013-14

Bench: Shri R. K. Panda & Ms Astha Chandra

For Respondent: S/Shri Suchek Anchaliya and
Section 10(38)Section 132Section 143(3)Section 147Section 148Section 153A

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Yogesh Transport Pvt Ltd, Raipur vs. Income Tax Officer, WD-1(1), Kolkata

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

ITA 1326/KOL/2025[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 133(6)Section 145(3)Section 194CSection 250Section 40Section 69C

numbers mentioned by the assessee were wrong and consequently disallowed 88% of the total lorry expenses which comes to %4,75,92,207/- as unexplained expenditure u/s 69C of the Act and added the same to the income of the assessee. Page |4 ITA No. 1326/KOL/2025 Yogesh Transport ... Transport Private Limited (A.Y. 2014-15) In conclusion, the appeal of the appellant is dismissed. The addition of Rs. 4,77,21,330/- as unexplained expenditure (Section 69C) and the related addition of 88% of lorry expenses as income are upheld due to the appellant's failure to provide credible

Kamlawati Chowhan, Howrah vs. ITO, Ward 46(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1247/KOL/2025[2018-19]Status: DisposedITAT Kolkata27 Oct 2025AY 2018-19

Bench: the CIT(A). However, due to non-compliance on consecutive dates, the CIT(A) dismissed the appeal ex parte. The assessee has now preferred the present appeal before the Tribunal, contending that the authorities below passed the orders without affording a reasonable opportunity to substantiate its claim with supporting evidence. The assessee, therefore, prayed that one more opportunity may be granted to substantiate its case before the Assessing Officer.

Section 131Section 148Section 148ASection 250Section 69C

purportedly purchased goods. On the basis of information gathered, the Assessing Officer made an addition of ₹ 1,67,67,679/- treating the same as unexplained expenditure under Section 69C of the Act and completed the assessment accordingly. 3. Aggrieved, the assessee preferred an appeal before the CIT(A). However

DCIT, CC-6(1), Mumbai, Bkc vs. Rajarampuri Motipuri Gosavi, Thane

In the result, all the grounds of appeal and consequently, the appeal filed by the Revenue are dismissed

ITA 3858/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Oct 2025AY 2021-22

Bench: Shri Sandeep Gosain & Shri Prabhash Shankardeputy Commissioner Of V/S. Rajarampuri Motipuri Income Tax, Central Circle – बनाम Gosavi 6(1) 1002 Steppes Vasant Lawns, Room No. 445, 4Th Floor, Pokharan Road No. 2, Kautilya Bhavan, Bandra Eastern Express Highway, Kurla Complex, Bandra Subhash Nagar, Thane – 400 (East), Mumbai – 400 051, 601, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Abjpg2425M Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Mr. Subodh Ratnaparkhi,ARFor Respondent: Shri Annavaran Kosuri, (Sr. AR)
Section 132Section 143(3)Section 148Section 69C

source of cash payment of Rs. 1,50,00,000/- for transfer and posting and made addition u/s. 69C of the Act as Unexplained expenditure. 4. Aggrieved, the assessee preferred appeal before the ld.CIT(A). Before him he pleaded the same contentions as made before the AO and denying ... addition is on a factually incorrect premise. The present addition was made expressly u/s 69C of the Act, holding the sum to be unexplained expenditure. The provisions of section 69C were incorrectly applied, as before invoking the provisions, it was incumbent to first establish that the respondent had in fact