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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

Jai Mata Di Om, Thane vs. Pr. Comm. of Income Tax, Thane-1, Thane

In the result, the appeal of the assessee is allowed

ITA 3342/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Oct 2025AY 2021-22

Bench: Shri Amit Shukla & Shri Prabhash Shankar

For Appellant: Shri Subodh Ratnaparkhi, ARFor Respondent: Shri Vivek Perampurna (CIT-DR)
Section 143Section 143(3)Section 263Section 69C

treated the expenses claimed by the assessee on account of Labour Charges paid to Mr. Kalyanji B. Shah and Mr. Haresh Naresh Tare as unexplained expenditure under section 69C of the Act as the same were not satisfactorily explained. However, the AO proceeded to make 50% of the gross payments ... provisions of Page | 11 ITA No. 3342/Mum/2025 A.Y. 2021-22 Jai Mata Di OM section 69C of the Act treating it to be unexplained expenditure. We are afraid,even this view of the ld.PCIT may be subjected to debate as to whether the expenses duly reflected in the books

ACIT-2(3)(1), Mumbai vs. Sterling Holiday Resorts Ltd., Mumbai

Appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 942/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Oct 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Dr. Kishor Dhule, CIT-DR
Section 250Section 69CSection 6C

difference between the amount of rent debited in the profit and loss account and the amount reported in the tax audit report as unexplained expenditure u/s. 69C. In this regard, we notice that the assessee has submitted the detailed reconciliation which is reproduced as under: 6. The assessee along with ... where the source is explained. In this regard it is relevant to look at the provisions of Section 69C which read as under: 69C- Unexplained expenditure, etc. Where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditure

Sterling Holiday Resorts Limited, Tamil Nadu vs. Deputy Commissioner of Income Tax - Circle 2(3)(1), Mumbai

Appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 845/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Oct 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Dr. Kishor Dhule, CIT-DR
Section 250Section 69CSection 6C

difference between the amount of rent debited in the profit and loss account and the amount reported in the tax audit report as unexplained expenditure u/s. 69C. In this regard, we notice that the assessee has submitted the detailed reconciliation which is reproduced as under: 6. The assessee along with ... where the source is explained. In this regard it is relevant to look at the provisions of Section 69C which read as under: 69C- Unexplained expenditure, etc. Where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditure

ACIT CC-6(1), Mumbai, Bkc vs. Vinaykumar Sudhakar Deshpande, Solapur, Maharashtra

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

ITA 6278/MUM/2024[2021-22]Status: DisposedITAT Mumbai27 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassistant Commissioner Of V/S. Vinaykumar Sudhakar Income Tax, Central Circle- 6(1) बनाम Deshpande Room No. 445, 4Th Floor, 528, Deshpande Lane, Bandra Kurla Complex, Bandra Near Bank Sangola, (East), Mumbai – 400 051, Solapur – 413 307, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Abcpd0198H Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Satyaprakash Singh,ARFor Respondent: Shri Leyaqat Ali Aafaqui, (Sr. DR)
Section 132Section 132(4)Section 143(3)Section 148Section 69C

after making addition of Rs. 3,50,00,000/- u/s. 69C of the Act treating the said entry as Unexplained expenditure. 4. In the subsequent appeal before the first appellate authority, he contested the impugned addition. The ld.CIT(A) observed that search account u/s. 132 of the Act was conducted ... used to the detriment of the respondent. 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

Income Tax Officer, Income Tax Office vs. Ritu Bala, Faridabda

In the result, the appeal of Revenue is dismissed

ITA 3621/DEL/2024[2018-19]Status: DisposedITAT Delhi27 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2018-19 Income Tax Officer, Ritu Bala, Vs. Faridabad 4237 Indra Prashtha Colony, Haryana Faridabad – 121 001 Haryana Pan :Bdhpb1495B (Appellant) (Respondent)

Section 142(1)Section 144Section 144BSection 148Section 148ASection 250Section 250(4)Section 69C

Whether on the facts and circumstances of case Ld CIT(A) is correct in deleting the addition on account of Bogus purchases and unexplained expenditure even when assessee deliberately stone walled efforts at enquiring into her affairs by failing to respond to statutory notices? 4. Whether on the facts ... circumstances of case Ld CIT(A) is correct in deleting the addition of Rs.4,23,21,000/ on account of unexplained expenditure u/s 69C even when assessee failed to discharge her onus of explaining such abnormally high cash withdrawals both during assessment and appellate proceedings? 5. Whether on facts

Asst. Commissioner of Income Tax Central Circle 3, Delhi vs. Ved Prakash Chanana, Delhi

In the result, the appeal of the assessee for AY 2018-19 is allowed

ITA 4993/DEL/2024[2018-19]Status: DisposedITAT Delhi24 Oct 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 127(1)Section 132Section 143(1)Section 143(2)Section 153ASection 69A

matching amount is loan given by Mr. Bhushan Dua to Sh. Ved Chanana then the argument of the AO that the cash payment is unexplained expenditure will not hold. The whole argument of the AO is based upon matching the cheque payment and considering the other corresponding amounts as cash ... payments in the nature of unexplained expenditure. When the nature of one matching cheque payment is loan and not salary paid to Sh. Ved Prakash Chanana then why would the company pay cash of similar amount against the alleged cheque payment. 13. Further, it is submitted that the rough jottings

Surinder Kumar Chhabra, Gurgaon vs. Circle 4(1), Gurgaon

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

ITA 4776/DEL/2024[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 143Section 147Section 148Section 69C

proved by the assessee and, the AO made an addition of Rs. 34,82,667/- by treating it as unexplained expenditure in the books of the assessee and taxed it u/s 69C of the Act, 1961. 3. Aggrieved, the assessee preferred an appeal before the learned CIT(A). 4. Before

Ved Prakash Chanana, Delhi vs. ACIT CC- 3, Delhi

In the result, the appeal of the assessee for AY 2018-19 is allowed

ITA 4644/DEL/2024[2019-20]Status: DisposedITAT Delhi24 Oct 2025AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 127(1)Section 132Section 143(1)Section 143(2)Section 153ASection 69A

matching amount is loan given by Mr. Bhushan Dua to Sh. Ved Chanana then the argument of the AO that the cash payment is unexplained expenditure will not hold. The whole argument of the AO is based upon matching the cheque payment and considering the other corresponding amounts as cash ... payments in the nature of unexplained expenditure. When the nature of one matching cheque payment is loan and not salary paid to Sh. Ved Prakash Chanana then why would the company pay cash of similar amount against the alleged cheque payment. 13. Further, it is submitted that the rough jottings

Ved Prakash Chanana, Delhi vs. ACIT CC 03, Delhi

In the result, the appeal of the assessee for AY 2018-19 is allowed

ITA 4643/DEL/2024[2018-19]Status: DisposedITAT Delhi24 Oct 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Jitender Singh, CIT DR
Section 127(1)Section 132Section 143(1)Section 143(2)Section 153ASection 69A

matching amount is loan given by Mr. Bhushan Dua to Sh. Ved Chanana then the argument of the AO that the cash payment is unexplained expenditure will not hold. The whole argument of the AO is based upon matching the cheque payment and considering the other corresponding amounts as cash ... payments in the nature of unexplained expenditure. When the nature of one matching cheque payment is loan and not salary paid to Sh. Ved Prakash Chanana then why would the company pay cash of similar amount against the alleged cheque payment. 13. Further, it is submitted that the rough jottings

Deputy Commissioner of Income Tax, Delhi vs. Scan Holdings Private Limited, Delhi

Appeal is dismissed

ITA 3753/DEL/2024[2008-09]Status: DisposedITAT Delhi24 Oct 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2008-09] Dcit, M/S Scan Holdings (P) Ltd., Circle-22(2), Room No.- 225E F-4, Shopping Complex, C.R. Building, I.P. Estate, Vs A-Block, Meera Bagh, New Delhi-110002 Delhi-110087. Pan- Pan- Aabcs0852N Revenue Assessee C.O. No.- 38/Del/2025 Arising Out Of Ita No.3753/Del/2024 [Assessment Year: 2008-09] M/S Scan Holdings (P) Ltd., Dcit, F-4, Shopping Complex, Circle-22(2), Room No.- 225E A-Block, Meera Bagh, Vs C.R. Building, I.P. Estate, Delhi-110087. New Delhi-110002 Pan- Aabcs0852N Assessee Revenue

Section 143(2)Section 143(3)Section 148Section 14A

under: “6.3 Ground of appeal No. 7 assails the action of the AO in holding an investment made in earlier years to be unexplained expenditure under section 68. The A.O noted from the balance sheet of the appellant company that it had invested Rs. 265734/- in Joint Venture of Scan

Kailash Gahlot, New Delhi vs. DCIT, Central Circle-4, New Delhi

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

ITA 3431/DEL/2023[2015-16]Status: DisposedITAT Delhi24 Oct 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.3431/Del./2023, A.Y. 2015-16 Kailash Gahlot Deputy Commissioner Of C-6/6172, Vasant Kunj, Income Tax, New Delhi Vs. Central Circle-4, Pan: Aajpg2849N New Delhi (Appellant) (Respondent) Appellant By Sh. Vinod Kumar Bindal, Ca Sh. Anmol Jha, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 28/07/2025 Date Of Pronouncement 24/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2015-16 Is Directed Against The Order Dated 30.09.2023 Of The Commissioner Of Income Tax (Appeals)-23, New Delhi [‘Cit(A)’].

Section 115BSection 132(4)Section 153DSection 69C

raised following grounds: “1. The CIT(A) erred in law and on facts in confirming an addition of Rs. 42,98,086/- as unexplained expenditure u/s 69C of the Act by holding the diary of Mr. Rohit Sharma seized from the office of the assessee as belonging to the assessee ... record should be deleted. 2. The CIT(A) erred in law and on facts in confirming the addition of Rs 42,98,086/- as unexplained expenditure u/s 69C of the Act being the amounts mentioned in a diary seized from his office premises as expenses incurred by the appellant during

Mr.Mohamed Meera Wahitha, Sivagangai vs. ACIT, Circle-1, Karaikudi

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

ITA 1955/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Oct 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. No.1955/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Mohamed Meera Wahitha, Vs. The Assistant Commissioner Of 13-3/12-H, Bungalow Oorani Street, Income Tax, Puduvayal, Karaikudi Taluk, Circle 1, Sivagangai 630 108. Karaikudi. [Pan:Aajpw6483G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri M.K. Rangasamy, C.A. ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.09.2025 घोषणा की तारीख /Date Of Pronouncement : 22.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 10 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer

For Appellant: Shri M.K. Rangasamy, C.AFor Respondent: Ms. E. Pavuna Sundari, Addl. CIT
Section 131Section 133ASection 44ASection 69Section 69A

relevant to assessment year concerned, in which the assessee is found to be the owner of such money, bullion, jewellery or valuable article or unexplained expenditure, if, the such expenditure or such money etc., are not recorded in the books of accounts, if any, maintained by assessee for any source

Geetha Mehra, Chennai vs. DCIT Cen Cir 44, Mumbai

Accordingly, the ground raised in this regard is dismissed as not pressed

ITA 4065/MUM/2016[2004-05]Status: DisposedITAT Mumbai22 Oct 2025AY 2004-05

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Prashant S. Ghumare, AR
Section 132Section 153ASection 250Section 68Section 69C

noticed from the perusal of bank statements that assessee's withdrawals towards personal expenses are very low. The AO accordingly made adhoc addition as unexplained expenditure which was confirmed by the CIT(A) in the first round. The coordinate bench of the Tribunal on further appeal remitted the issue back

Ganesh Puranchand Agrawal, Nagpur vs. ITO Ward 4(1), Nagpur

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

ITA 575/NAG/2025[2019-20]Status: DisposedITAT Nagpur17 Oct 2025AY 2019-20

Bench: Shri Pavan Kumar Gadaleganesh Puranchand Agrawal, 120, Chikli Layout, Kalamna Marketroad, ……………. Appellant Nagpur-440008, Maharashtra. Pan – Afypa6620B V/S Income Tax Officer Ward–4(1), ……………. Respondent Nagpur-440008, Maharashtra. Assessee By: Shri.Abhishek Kumar.Ar Revenue By :Shri.Surjit Kumar Saha.Sr.Dr Date Of Hearing – 17/10/2025 Date Of Order –17/10/2025

For Appellant: Shri.Abhishek Kumar.ARFor Respondent: Shri.Surjit Kumar Saha.Sr.DR
Section 147Section 234ASection 234FSection 271ASection 69C

Whether the Hon'ble CIT(A) is justified in law and fact in affirming addition to the tune of Rs. 25,61,869/ as unexplained expenditure u/s 69C of the Act 3. Whether Hon'ble CIT(A) is justified in law and fact in affirming that the purchases made from ... judicial decisions and came to the conclusion that the assessee could not substantiate the genuineness of the transactions and made the addition of unexplained expenditure u/sec 69C of Rs.25,61,869/– and assessed the total income of Rs.33,59,609/– and passed the order u/sec147r.w.s.144B dated 19/01/2024. Aggrieved

Raghunath Narayan Dhote, Nagpur vs. ITO Ward 1(2), Nagpur

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

ITA 505/NAG/2025[2018-2019]Status: DisposedITAT Nagpur17 Oct 2025AY 2018-2019

Bench: Shri Pavan Kumar Gadale

For Appellant: Shri.Naresh Jakhotia.A.RFor Respondent: Shri.Surjit Kumar Saha.Sr.DR
Section 56(2)(x)Section 69A

said amounts are not reflected in the bank statement and treated aggregate amount of Rs.11,00,00/- as unexplained expenditure u/sec69C of the Act. And the last disputed issue due to variation in the market value and the purchase cost of the property, Assessing Officer has invoked the provisions

DCIT, Central Circle-1(1), Kolkata vs. Rajesh Kumar Kedia, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are allowed

ITA 138/KOL/2025[2019-20]Status: DisposedITAT Kolkata17 Oct 2025AY 2019-20

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

For Appellant: S/Shri S.M Surana &For Respondent: Shri Sanat Kumar Raha, DR
Section 132(1)Section 132(4)Section 143(1)Section 147Section 148Section 148ASection 69A

made. At the same time, the learned AO also added brokerage at the rate of 2% which comes to ₹17,60,000/- as unexplained expenditure in the assessment framed u/s 147/143(3) of the Act dated 06.09.2023. 07. In the appellate proceedings, the learned CIT (A) deleted the addition after

DCIT, Central Circle-1(1), Kolkata vs. Rajesh Kumar Kedia, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are allowed

ITA 137/KOL/2025[2016-17]Status: DisposedITAT Kolkata17 Oct 2025AY 2016-17

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

For Appellant: S/Shri S.M Surana &For Respondent: Shri Sanat Kumar Raha, DR
Section 132(1)Section 132(4)Section 143(1)Section 147Section 148Section 148ASection 69A

made. At the same time, the learned AO also added brokerage at the rate of 2% which comes to ₹17,60,000/- as unexplained expenditure in the assessment framed u/s 147/143(3) of the Act dated 06.09.2023. 07. In the appellate proceedings, the learned CIT (A) deleted the addition after

Kritika Jain, New Delhi vs. ITO Ward 36(1), New Delhi

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

ITA 777/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishraita No.777/Del./2025, A.Y. 2019-20 Kritika Jain Income Tax Officer, C/O. Ds Legal & Associates, Ward 36(1), B-50, Lgf, South Extension-Ii, Vs. Civic Centre, New Delhi Minto Road, New Delhi Pan: Aftpa6657B (Appellant) (Respondent) Appellant By Sh. Shaantanu Jain, Advocate Sh. Dipanshu Jain, Advocate Ms. Jahanvi Khanna, Advocate Respondent By Sh. Dayainder Singh Sidhu, Cit-Dr Date Of Hearing 29/07/2025 Date Of Pronouncement 17/10/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Of The Assessee For Assessment Year (‘Ay’) 2019-20 Is Directed Against The Order Dated 22.01.2025 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 143(2)

Rs.8,20,000/- is hereby disallowed, treating the same as inflation of purchases to evade quantum of profit element embedded. Therefore, treated as unexplained expenditure u/s 69C of the IT. Act, and the same is added back to the total income of the assessee. Accordingly, penalty 4 Kritika Jain proceedings ... under: “5.3 During the appellate proceedings, the appellant claimed that all the purchases were genuine and the AO erred in treating them as unexplained expenditure. The Investigation/enquiries by the Government Agencies have proved that the above parties were engaged in giving bogus bills for the sake of commission. In fact

Deputy Commissioner of Income Tax, Jhandewalan, New Delhi vs. Israni Buildwell Private Limited, Delhi

ITA 3132/DEL/2024[2014-15]Status: HeardITAT Delhi17 Oct 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 148Section 194CSection 194ISection 68Section 69Section 69C

discharge its onus during assessment proceedings? 2) The Ld. CIT(A) has erred in deleting the addition of Rs.17,92,814/-on account of unexplained expenditure under section 69C of the Act even 1 Israni Buildwell Pvt. Ltd. when the assessee failed to discharge its onus during assessment proceedings ... Rs.17,92,814/- (4,85,000 + 13,07,814) is added to the total income of the assessee company on account of unexplained expenditure u/s 69C of the Income Tax Act, 1961 to the best of my judgment.” 3.4 Further, the Ld. AO also taxed the assessee’s Time Deposit

Raheja Developers Limited, New Delhi vs. DCIT, Central Circle 19, New Delhi

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

commission paid to the parties u/s 69C of the Act as unexplained expenditure. 4. Aggrieved by the assessment orders dated 31/12/2018 and 26/12/2019 respectively for Assessment Year 2011-12 and 2012-13, Assessee preferred two Appeals before the Ld. CIT(A). The Ld. CIT(A) vide orders dated 12/06/2023 dismissed