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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

Ketan Ramanlal Shah, Santacruz (W) vs. Assistant Commissioner of Income Tax, Central Circle 1(4), Mumbai, Pratishtha Bhavan, Old Cgo Annexe, Maharishi Karve Road

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4372/MUM/2024[2019-20]Status: DisposedITAT Mumbai29 May 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Jatin Rajnikant Shah, Santacruz(E), Mumbai vs. Assistant Commissioner of Income Tax-Central Circle 1(4), Mumbai, Pratishtha Bhavan, Old Cgo Annexe, Maharishi Karve Road

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4340/MUM/2024[2015-16]Status: DisposedITAT Mumbai29 May 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Jatin Rajnikant Shah, Santacruz(E), Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 1(4), Mumbai, Pratishtha Bhavan, Old Cgo Annexe, Maharishi Karve Road

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4338/MUM/2024[2016-17]Status: DisposedITAT Mumbai29 May 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Jatin Rajnikant Shah, Santacruz (E), Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 1(4), Mumbai, Pratishtha Bhavan, Old Cgo Annexe, Maharishi Karve Road

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4336/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 May 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Jatin Rajnikant Shah, Santacruz (E), Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 1(4), Mumbai, Pratishtha Bhavan, Old Cgo Annexe, Maharishi Karve Road

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4335/MUM/2024[2018-19]Status: DisposedITAT Mumbai29 May 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Jatin Rajnikant Shah, Santacruz (E), Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 1(4), Mumbai, Pratishtha Bhavan, Old Cgo Annexe, Maharishi Karve Road

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4334/MUM/2024[2019-20]Status: DisposedITAT Mumbai29 May 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Ketan Ramanlal Shah HUF, Mumbai vs. JCIT Central Circle 1(4), Mumbai

In the result, appeal of the Revenue is dismissed and appeal

ITA 4137/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 May 2025AY 2020-21
Section 14A

Those ledgers which was both debit and credit entries are considered for peak working. Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act. Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- Α.Υ. Receipts

Vinay Ramanlal Shah HUF, Mumbai vs. ACIT Central Circle 1(4), Mumbai

In the result, appeal of the Revenue is dismissed and appeal of the assessee is partly allowed

ITA 4136/MUM/2024[2015-16]Status: DisposedITAT Mumbai29 May 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 14ASection 69C

Those ledgers which was both debit and credit entries are considered for peak working.  Those ledgers which only have the debit entries considered as unexplained expenditure u/s 69C of the Act.  Those ledgers which have only credit entries considered as unexplained income u/s 69A of the Act. The Investigation Wing ... receipts, the same has been considered as unexplained money u/s 69A and wherever, the ledger contain only payments, the same has been considered as unexplained expenditure u/s 69C. In the this way, the year wise addition made in the hands of the assessee is tabulated as under:- A.Y. Receipts Payment

Madhav Krg Limited, Patiala vs. DCIT C C, Patiala

In the result, Assessee’s appeal is allowed

ITA 291/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh28 May 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 291/Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 Madhav Krg Limited, Dcit, Vill. Akalgarh, Amloh, बनाम Central Circle, Bhadson Road, Patiala Vs. Near Roll Plaza, Distt. Patiala "थायी लेखा सं./Pan No: Aadcm6458N अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Ashok Goel, Ca राज"व क" ओर से/ Revenue By : Sh. Ved Parkash Kalia, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 12.03.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 28.05.2025 आदेश/Order

For Appellant: Shri Ashok Goel, CAFor Respondent: Sh. Ved Parkash Kalia, Sr.DR
Section 131Section 142(1)Section 143(2)Section 69C

purchases of Rs. 2,58,837/- from M/s. Shree Ganpati Enterprises Prop. Sh. Pawan Mishra as bogus purchases and treating the same as unexplained expenditure to be deemed income of the assessee u/s 69C is found sustainable. The AO has duly mentioned the facts and the legal position in support

Assistant Commissioner of Income Tax-16(1), Mumbai vs. Matrix Publicitiies and Media Pvt Ltd, Mumbai

In the result, appeal by the revenue is dismissed and cross objection by the assessee is allowed

ITA 5174/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 May 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2017-18 Assistant Commissioner Vs Matrix Publicities & Of Income Tax-16(1), Media India Pvt. Ltd. Mumbai 7Th Floor Bay 99, The Orb, Sahar P & T Colony, S.O., Mumbai 400099 (Pan: Aadcm8510H) Appellant Respondent

For Appellant: Shri Nikhil Tiwari, CAFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr DR
Section 143(3)Section 40Section 69C

Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in allowing the claim of Unexplained expenditure disallowed u/s 69C. 3. Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in allowing the unexplained nature of the software expenses ... made for this amount on account oof non deduction of tax at source resulting into a disallowance u/s 40(a)(i) and also as unexplained expenditure u/s 69C since source for the same not explained. Assessee has claimed an expense of Rs. 5,29,55,091/- out of the said

Vinod Hirachand Sanghvi, Mumbai vs. ACIT, Circle-19(3), Lalbaug, Mumbai

In the result, the grounds of appeal raised by the

ITA 4340/MUM/2023[2013-14]Status: DisposedITAT Mumbai27 May 2025AY 2013-14

Bench: Shri Pawan Singh & Girish Agrawal(Physical Hearing) Vinod Hirachandsanghvi Acit, Circle-19(3), Mumbai 315, Gr. Floor, Gogari Mansion, Vs Piramal Chamber, Lalbaug, 1 Carpenter Street, Charni Road, Parel, Mumbai, Mumbai-400004. Maharashtra-400012. [Pan No. Afmps3101F Appellant / Assessee Respondent / Revenue

Section 10(38)Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

laws treated the long term capital gain as unexplained and added under section 68. The assessing officer also added 2.00% of capital gain as unexplained expenditure. Thereby made further addition of Rs. 55,800/- in assessment order dated 28.12.2017 passed under section 143 read with section 157. 3. Aggrieved ... upheld the action of assessing officer. Once the disallowance of claim under section 10(38) was upheld, the addition of unexplained expenditure added @ 2.00% of sale consideration 7 Vinod Hirachand Sanghvi was also upheld. Further, aggrieved the assessee has filed present appeal before Tribunal. 5. We have heard the submission

Kashyap M Vora (HUF), Mumbai vs. Income Tax Officer, Ward, 19(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3394/MUM/2024[2012-13]Status: DisposedITAT Mumbai26 May 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri K. Gopal, AdvFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 147Section 148Section 68Section 69C

NFAC has erred in confirming the action of Assessing Officer in making addition of Rs.1,25,504/- on account of unexplained expenditure under section 69C of the Act for alleged commission payment for procuring the alleged accommodation entry merely on the basis of conjecture and surmises. 3. Briefly stated, facts ... respect of the sale proceeds of the shares and also confirmed the addition u/s 69C of the Act on account of unexplained expenditure in form of commission paid. 6. Before us, the ld.DR has supported the orders of authorities below. Per contra, the ld.AR has reiterated the contentions as made

Kalpana Vijay Kadam, Pune vs. ITO, Ward 2(2), Pune

In the result, appeal of the assessee is Partly Allowed

ITA 841/PUN/2025[2016-17]Status: DisposedITAT Pune23 May 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.841/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Kalpana Vijay Kadam, V The Income Tax Officer, Fi 13, Janki Heights, S.No.250, S. Ward-2(2), Pune. Baner D P Road, Aundh, Pune – 411007. Maharashtra. Pan: Axzpk4350P Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas P. Bora – Ar Revenue By Shri Manish Mehta – Addl.Cit(Dr) Date Of Hearing 15/05/2025 Date Of Pronouncement 23/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 06.02.2025 For The A.Y.2016-17. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In Law, The Learned Commissioner Of Income Tax (Appeals) [Cit(A)] Erred In Passing An Ex-Parte Order Without Affording A Reasonable Opportunity To The Appellant. The Order Was Solely Based On The Observations Of The Assessing Officer (Ao) In The

Section 139(1)Section 147Section 148Section 148ASection 250Section 69C

Mr.Vijay Laxmanrao Kadam. ITA No.841/PUN/2025 [A] 8.4 The Assessing Officer(AO) has made addition u/s.69C of the Act. Section 69C is reproduced as under : “Unexplained expenditure, etc. 69C. Where in any financial year an assessee has incurred any expenditure and he offers no explanation about the source of such expenditure ... income of the assessee for such financial year : Provided that, notwithstanding anything contained in any other provision of this Act, such unexplained expenditure which is deemed to be the income of the assessee shall not be allowed as a deduction under any head of income.” 8.5 Thus, Section

ACIT, Mumbai vs. Flipspaces Technology Labs Pvt. Ltd., Mumbai

In the result the appeal filed by the revenue stands dismissed

ITA 2055/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 May 2025AY 2022-23

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

Section 133(6)Section 143(2)Section 68Section 690Section 69C

Ld.CIT(A) erred in shifting the burden of proof from the assessee to the department regarding unexplained cash credits under Section 68 and unexplained expenditure under Section 690 when the onus to prove the genuineness of transactions lay on the assessee? 3. Whether the Ld.CIT(A) was justified in accepting ... substantiate, the Ld.AO treated the same as unexplained cash credit u/s.68 of the Act. The Ld.AO also treated the said amount as unexplained expenditure u/s.69C of the Act. Aggrieved by the order of the Ld.AO assessee preferred appeal before the Ld.CIT(A). 5 ITA No.2055/Mum/2025; A.Y. 2022-23 Flipspaces Technology

Diesh Kumar Goyal, Kota vs. ITO, Ward-1(1), Kota

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

ITA 32/JPR/2025[2010-11]Status: DisposedITAT Jaipur22 May 2025AY 2010-11
For Appellant: Sh. Rajendra Sisodia, Adv
Section 143(3)Section 271(1)(c)Section 274Section 68Section 69

clearly stated that the same did not pertain to him. But the AO made the addition of the impugned amount holding it to be unexplained expenditure u/s 69C. 4.2 On appeal, the Ld.CIT(A) held cash creditors to the extent of Rs.4,37,000/- as unsubstantiated, while in respect

Steel and Scrap Supplier, Bhavnagar vs. Assistant Commissioner of Income Tax, Circle-1, Bhavnagar

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

ITA 541/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad22 May 2025AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sarju Mehta, A.RFor Respondent: Shri V. Nandakumar, CIT DR
Section 133(6)Section 148Section 69C

added to Steel And Scrap Supplier vs. ACIT Asst. Year –2014-15 - 3– the assessee’s income as unexplained expenditure under Section 69C of the Act. 4. In appeal, Ld. CIT(A) dismissed the appeal of the assesse with the following observations: “7.1 I also find that the assessee

Income Tax Officer, Ward-1, Jalna vs. Nishatbegum Syed Baba Rasool Patel, Parbhani

In the result, the appeal of assessee is allowed

ITA 1351/PUN/2024[2017-18]Status: DisposedITAT Pune22 May 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18 Ito, Ward – 1, Jalna Nishatbegum Syed Baba Rasool Patel Patel Show Company, Vs. Dr. Ambedkar Road, Parbhani – 431401 Pan: Abxpp9642B (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Ramnath P Murkunde Date Of Hearing : 13-05-2025 Date Of Pronouncement : 22-05-2025 O R D E R

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 115BSection 131Section 133ASection 133A(1)Section 139Section 143(1)Section 143(2)Section 69Section 69C

assessee to explain as to why the excess stock found during the course of survey action amounting to Rs.3,20,25,540/- and the unexplained expenditure on furniture and fixtures at Rs.19,98,263/- shall not be brought to tax u/s 69 r.w.s. 115BBE ... held that the income offered during the survey action u/s 133A(1) of the Act by the assessee amounting to Rs.19,98,263/- as unexplained expenditure under the provisions of section 69C r.w.s. 115BBE of the Act and the unexplained stock of Rs.3,20,25,540/- be taxed under

Deputy Commissioner of Income Tax, Central Circle - 2(4), Bengaluru vs. Sri Adichunchanagiri Shikhana Trust, Mandya

ITA 1207/BANG/2024[2011-12]Status: DisposedITAT Bangalore22 May 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Bharath L, CAFor Respondent: Smt. Vidya K., Jt.CIT (DR)(ITAT), Bengaluru
Section 143(3)Section 234ASection 69ASection 69C

ought to have applied the principle of telescoping and granted appropriate relief. The amount of Fee Refund amounting to Rs.7,65,54,000/- and unexplained expenditure of Rs 1,21,75,000/- requires to be telescoped with alleged unaccounted receipts amounting to Rs.7,74,75,000/- and the balance alone ... circumstances of the case, the Ld. CIT(A) was right in restricting disallowance to the extent of Rs.76,56,000/- made on account of unexplained expenditure of Rs.1,21,75,000/, 4. Whether on the facts and circumstances of the case, the Ld. CIT(A) was right in restricting disallowance

M/S. Sri . Adichunchanagiri Shilkshana Trust, Mandya vs. The Deputy Commissioner of Income Tax, Central Circle-2(4), Bengaluru

ITA 1096/BANG/2024[2011-12]Status: DisposedITAT Bangalore22 May 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Bharath L, CAFor Respondent: Smt. Vidya K., Jt.CIT (DR)(ITAT), Bengaluru
Section 143(3)Section 69ASection 69C

ought to have applied the principle of telescoping and granted appropriate relief. The amount of Fee Refund amounting to Rs.7,65,54,000/- and unexplained expenditure of Rs 1,21,75,000/- requires to be telescoped with alleged unaccounted receipts amounting to Rs.7,74,75,000/- and the balance alone ... circumstances of the case, the Ld. CIT(A) was right in restricting disallowance to the extent of Rs.76,56,000/- made on account of unexplained expenditure of Rs.1,21,75,000/, 4. Whether on the facts and circumstances of the case, the Ld. CIT(A) was right in restricting disallowance

Compact Agencies Pvt. Ltd., Kolkata vs. DCIT/ACIT, Circle 3(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 200/KOL/2025[2017-18]Status: DisposedITAT Kolkata21 May 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.200/Kol/2025 Assessment Year: 2017-18 Compact Agencies Pvt. Ltd……………………………………...….……….Appellant Room No.1A, 20B, West Bengal, East India House, Bbd Bag, West Bengal-700069. [Pan: Aadcc6607K] Vs. Dcit/Acit, Circle-3(1), Kolkata.….....................……........……...…..…..Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Assessee. Shri Raja Sengupta, Cit, Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 15, 2025 Date Of Pronouncing The Order : May 21, 2025 Order Per Sonjoy Sarma: This Appeal Of The Assessee For The Assessment Year 2017-18 Is Directed Against The Order Dated 19.08.2024 Passed By The National Faceless Appeal Centre [Hereinafter Referred To As ‘The ‘Ld. Cit(A)’]. 2. At The Outset, It Is Noted That There Is A Delay Of 88 Days In Filing The Instant Appeal Before The Tribunal. The Assessee Has Submitted An Application For Condonation Of Such Delay Explaining Reasons For The Delay. We, After Perusing The Petition Made In The Application, Satisfy That There Were Bona Fide & Sufficient Reasons For Such Delay. We, Therefore, Condone The Delay & Admit This Appeal For Adjudication. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2017-18 By Declaring Total Income As Nil. Subsequently, The Case Of The Assessee Was Selected For

Section 142(1)Section 143(3)Section 14ASection 251(2)Section 69Section 69C

without issuing show-cause notice u/s 251(2) of the Act enhanced the income of the assessee by 3,52,22,603/- as unexplained expenditure u/s 69C of the Act. 5. Dissatisfied with the above order, the assessee preferred appeal before this Tribunal raising various issues involved in the appeal ... without having any exempt income earned. The ld. AR also stated that the issue of enhancement of income at Rs.3,52,22,603/- as unexplained expenditure u/s 69C by the ld. CIT(A), is also bad in law and not justified as the ld. CIT(A) failed to issue