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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

Sameer Subhash Hosmani, Mumbai vs. ITO, Ward 35(3)(1), Mumbai

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

ITA 2412/MUM/2024[2013-2014]Status: DisposedITAT Mumbai14 Feb 2025AY 2013-2014

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalsameer Subhash Hosmani, Flat No. 1, Shreenath Dham, W.S. Road, Opp. Jana Seva Bank, Dahisar East, Mumbai - 400068 ……………. Appellant Maharashtra Pan: Adiph3121L V/S Ito, Ward 35(3)(1), Mumbai Kautilya Bhavan, Bandra Kurla Complex, ……………. Respondent Mumbai - 400051 Maharashtra Assessee By : Ms. Rakhi Dholakiya, Ca Revenue By : Shri Kiran Unavekar, Sr. Dr

For Appellant: Ms. Rakhi Dholakiya, CAFor Respondent: Shri Kiran Unavekar, Sr. DR
Section 132Section 148Section 153CSection 250Section 250(6)Section 56Section 69C

erred in confirming the addition of Rs. 64,550/- made by the Assessing Officer u/s 69C of the Act on account of alleged unexplained expenditure of the appellant towards i) Rs. 23,550/- as estimated annual household expenses and ii) Rs. 41,000/- as alleged cash payment made

DCIT, Central Circle 2, Rajkot vs. Aditya Birla Global Trading (India) Pvt. Ltd. (Swiss Singapore India Pvt. Ltd., Gandhidham

In the result, appeal filed by the assessee, in ITA No

ITA 353/RJT/2024[2017-18]Status: DisposedITAT Rajkot13 Feb 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)Section 195Section 37(1)Section 40

addition of Rs. 1,80,23,440/- made by the Id. assessing officer in respect of commission expenses alleging the same to be unexplained expenditure and thereby invoking section 69C 1.2 The Assessee therefore prays that the aforesaid addition be deleted." 44. Succinct facts qua the issue are that during ... rejected the above reply of the assessee and made addition of Rs. 1,80,23,440/-, to the total income of the assessee as unexplained expenditure u/s. 69C of the Act. 46. On appeal, the Id. CIT(A) confirmed the action of the assessing officer. The Id. CIT(A) just

Deputy Commissioner of Income Tax, Central Circle 2, Rajkot vs. Aditya Birla Global Trading(India) Pvt.Ltd. (Swiss Singapore India Pvt. Ltd.), Gandhidham

In the result, appeal filed by the assessee, in ITA No

ITA 284/RJT/2024[2016-17]Status: DisposedITAT Rajkot13 Feb 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)Section 195Section 37(1)Section 40

addition of Rs. 1,80,23,440/- made by the Id. assessing officer in respect of commission expenses alleging the same to be unexplained expenditure and thereby invoking section 69C 1.2 The Assessee therefore prays that the aforesaid addition be deleted." 44. Succinct facts qua the issue are that during ... rejected the above reply of the assessee and made addition of Rs. 1,80,23,440/-, to the total income of the assessee as unexplained expenditure u/s. 69C of the Act. 46. On appeal, the Id. CIT(A) confirmed the action of the assessing officer. The Id. CIT(A) just

Aditya Birla Global Trading (India) Private Limited, Gujarat vs. DCIT-ACIT Cent-2 RKT, Rajkot

In the result, appeal filed by the assessee, in ITA No

ITA 226/RJT/2024[2018-2019]Status: DisposedITAT Rajkot13 Feb 2025AY 2018-2019

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)Section 195Section 37(1)Section 40

addition of Rs. 1,80,23,440/- made by the Id. assessing officer in respect of commission expenses alleging the same to be unexplained expenditure and thereby invoking section 69C 1.2 The Assessee therefore prays that the aforesaid addition be deleted." 44. Succinct facts qua the issue are that during ... rejected the above reply of the assessee and made addition of Rs. 1,80,23,440/-, to the total income of the assessee as unexplained expenditure u/s. 69C of the Act. 46. On appeal, the Id. CIT(A) confirmed the action of the assessing officer. The Id. CIT(A) just

Aditya Birla Global Trading (India) Private Limited, Gujarat vs. Assistant Commissioner of Income Tax, Circle 1, Gandhihdam, Gandhidham, Gujarat

In the result, appeal filed by the assessee, in ITA No

ITA 225/RJT/2024[2015-2016]Status: DisposedITAT Rajkot13 Feb 2025AY 2015-2016

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 143(3)Section 195Section 37(1)Section 40

addition of Rs. 1,80,23,440/- made by the Id. assessing officer in respect of commission expenses alleging the same to be unexplained expenditure and thereby invoking section 69C 1.2 The Assessee therefore prays that the aforesaid addition be deleted." 44. Succinct facts qua the issue are that during ... rejected the above reply of the assessee and made addition of Rs. 1,80,23,440/-, to the total income of the assessee as unexplained expenditure u/s. 69C of the Act. 46. On appeal, the Id. CIT(A) confirmed the action of the assessing officer. The Id. CIT(A) just

Assistant Commissioner of Income Tax, Mumbai vs. Winning Moves Toys & Games Pvt Ltd, Mumbai

In the result, appeal of the revenue is dismissed

ITA 6390/MUM/2024[2018-19]Status: DisposedITAT Mumbai13 Feb 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: NoneFor Respondent: Shri Pushkaraj Bhangepatil, Sr. D/R
Section 144Section 148ASection 69C

absence of any details, the transactions with respect to import amounting to Rs.1,11,92,073/- was treated as assessee's own undisclosed and unexplained expenditure u/s 69C of the Act and the additions were made. 5. The assessee agitated the matter before the ld. CIT(A) and furnished necessary ... maintainable. Section 69C of the IT Act cannot be invoked for this kind of transaction. It is a deeming provision that deals with unexplained expenditure that is not recorded in the books of I.T.A. No. 6390/Mum/2024 4 accounts. In the present case the appellant company has submitted entire details

Madan Mohan Gahtori, Udham Singh Nagar vs. ACIT, U.S.Nagar

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

ITA 56/DDN/2023[2014-15]Status: DisposedITAT Dehradun12 Feb 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 131Section 144ASection 153ASection 244ASection 251(1)(a)Section 69ASection 69C

also held that the assessee had incurredday-to-day household expenditure of Rs.6,00,000/-. Accordingly, he taxed Rs.6,00,000/- as unexplained expenditure under section 69C of the Act. Consequentially, the scrutiny assessment was completed at income of Rs.11,97,350/-. 3.1 Aggrieved, the assessee filed appeal before

Darshan Shaileshkumar Kothari, Bhavnagar vs. The Dy.CIT., Circle-1(1), Ahmedabad

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

ITA 151/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad12 Feb 2025AY 2018-19

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2018-19 Vs. Darshan Shaileshkumar Kothari, Deputy Commissioner Of 0 Near Jain Upashray, Income-Tax, Limbda, Bhavnagar, Circle 1(1), Gujarat-364240 Bhavnagar [Pan : Eebpk 5909 F] अपीलाथ"/ अपीलाथ"/ (Appellant) अपीलाथ"/ अपीलाथ"/ " य " यथ"/ " य " य थ"/ थ"/ (Respondent) थ"/ Assessee By : Shri Parimal Sinh B. Parmar, Ar Revenue By : Adjournment Application Filed सुनवाई क$ तार"ख/Date Of Hearing : 21.11.2024 सुनवाई क$ तार"ख सुनवाई क$ तार"ख सुनवाई क$ तार"ख घोषणा क$ तार"ख /Date Of Pronouncement: 12.02.2025 घोषणा क$ तार"ख / घोषणा क$ तार"ख / घोषणा क$ तार"ख / आदेश/O R D E R आदेश/ आदेश/ आदेश/ Per Siddhartha Nautiyal:

For Appellant: Shri Parimal Sinh B. Parmar, ARFor Respondent: Adjournment application filed
Section 250Section 270ASection 271ASection 68Section 69C

deemed commission. 5. The Ld. CIT(A) has erred in law and on facts in confirming the disallowance of Rs.20,00,000/- as unexplained expenditure u/s. 69C of the Act. 6. The Ld. CIT(A) has erred in law and on facts in confirming the disallowance of Rs.15 ... unexplained expenditure u/s. 69C of the Act. 7. The Ld. CIT(A) has erred both in law and on the facts of the case in confirming the addition in spite of the fact that the Ld. AO did not appreciate necessary supporting documents produced by the Appellant in support

Ratna Infrastructure Projects Private Limited, Hyderabad vs. ITO, Ward-3(3), Hyderabad

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

ITA 132/HYD/2023[2012-13]Status: DisposedITAT Hyderabad12 Feb 2025AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: Shri B. Balakrishna, CIT-DR
Section 143(3)Section 148Section 40A(3)

documents seized and verification of books of accounts, the then learned Assessing Officer made an addition of Rs. 18,01,00,000/-, as unexplained expenditure/ disallowance u/s 40A(3) of the IT Act. Therefore, erred in confirming additions made by Assessing Officer in reassessment proceedings amounting to Rs.273

Sunil Narang, Hyderabad vs. Deputy Commissioner of Income Tax Central Circle-2(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 746/HYD/2020[2017-18]Status: DisposedITAT Hyderabad12 Feb 2025AY 2017-18
Section 119Section 132(1)Section 143(2)Section 143(3)Section 153A

making addition of Rs.1,30,88,750/- on the basis of transactions as per Whatsapp messages and Rs.75 lakhs on account of unexplained expenditure. 4. Aggrieved with the decision of Ld. AO, the assessee filed appeal before the Ld. CIT(A), who partly allowed the appeal of the assessee ... Rs.95 lakhs out of Rs.1,30,88,750/-, which was on account of whatsapp messages and Rs.75 lakhs, which was on account of unexplained expenditure. 5. Aggrieved with the order of Ld. CIT(A), the assessee is in appeal before us. The Ld. AR submitted that, their main grievance

ACIT CC -6(1), Mumbai, Bkc vs. Prashant Prakash Nilawar, Pnue

In the result, appeal of the assessee is partly allowed

ITA 5689/MUM/2024[2021-22]Status: DisposedITAT Mumbai12 Feb 2025AY 2021-22

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri Amol Kirtane,CIT-DR and Shri Mahesh Pamnani, Sr.DR
Section 132Section 143(2)Section 143(3)Section 148Section 65BSection 69ASection 69CSection 6C

deletion of Rs.14 lakhs made by ld. CIT(A) in respect of addition made by ld. Assessing Officer u/s.69C by holding it as unexplained expenditure. Accordingly, ground taken by the Revenue is dismissed and that of the assessee is allowed. 6. Now, we take up ground no.2 in the appeal ... assessee or Rucha Group. Ld. Assessing Officer not accepting the submissions of the assessee, proceeded to make the addition of the stated amount as unexplained expenditure u/s.69C. Before the ld. CIT(A), assessee reiterated its submissions. It was also asserted that ld. Assessing Officer did not make any efforts

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

In the result, appeal of the assessee is partly allowed

ITA 5073/MUM/2024[2021-2022]Status: DisposedITAT Mumbai12 Feb 2025AY 2021-2022

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2021-22

For Appellant: Shri Nishit Gandhi, ARFor Respondent: Shri Amol Kirtane,CIT-DR and Shri Mahesh Pamnani, Sr.DR
Section 132Section 143(2)Section 143(3)Section 148Section 65BSection 69ASection 69CSection 6C

deletion of Rs.14 lakhs made by ld. CIT(A) in respect of addition made by ld. Assessing Officer u/s.69C by holding it as unexplained expenditure. Accordingly, ground taken by the Revenue is dismissed and that of the assessee is allowed. 6. Now, we take up ground no.2 in the appeal ... assessee or Rucha Group. Ld. Assessing Officer not accepting the submissions of the assessee, proceeded to make the addition of the stated amount as unexplained expenditure u/s.69C. Before the ld. CIT(A), assessee reiterated its submissions. It was also asserted that ld. Assessing Officer did not make any efforts

Sarthak Ispat Pvt. Ltd., Raipur vs. Income Tax Officer-2(1), Raipur

ITA 431/RPR/2024[2012-13]Status: DisposedITAT Raipur11 Feb 2025AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 431/Rpr/2024 ("नधा"रण वष" Assessment Year: 2012-13) Sarthak Ispat Pvt. Ltd., V Income Tax Officer-2(1), Raipur S Udaya Society, Vivekanand Ashram, Raipur, 492001, C.G. Pan: Aalcs5029H (अपीलाथ"/Appellant) . (""थ" / Respondent) . िनधा"रती की ओर से /Assessee By : Shri Subhash Agrawal, Adv. राज" की ओर से /Revenue By : Shri S. L. Anuragi, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 29.01.2025 घोषणा की तारीख/Date Of Pronouncement : 11.02.2025

For Appellant: Shri Subhash Agrawal, AdvFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 68

discrepancies found during the Search & Seizure procedure, in absence of any explanation furnished by the assessee on account of unexplained expenditure rooted through or not in the books of account of the assessee for Rs.4,76,76,469/- and (iii) another addition doubting the genuineness of the interest payment

Jagdish Kumar Arora, Bhawanimandi vs. DCIT, Central Circle- Kota, Kota

In the result, the appeal of the assessee is allowed

ITA 1195/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Feb 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-Sr. DR
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

will have application. The incomes mentioned under these sections are not specific to any head of income. Section 69C even clearly mentions that such unexplained expenditure will not be deductible under any head of income. Loans given / stock in hand / loan received etc. are otherwise not taxable as these ... income from 'other sources' because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case may be, have not been explained or satisfactorily explained. Section

P. Maneklal and Co., Vadodara vs. The Dy.CIT, Central Circle-1, Vadodara

In the result, the appeal of the Assessee is allowed

ITA 1864/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad11 Feb 2025AY 2019-20

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri V.K. Mangla, Sr DR
Section 115BSection 131Section 250Section 69ASection 69C

ought to have been held that all the purchases are duly recorded in the books of accounts and there is no unexplained expenditure. (3) That on facts, and in law, the learned AO has grievously erred in taxing the alleged bogus purchases u/s 115BBE of the Act." 3. The brief

Sunita Jajoo, Surat vs. ITO Ward 2(2)(4), Surat

In the result, assessee’s appeal is allowed

ITA 882/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

subject, the learned CIT(A) has erred in confirming action of Assessing Office in making addition of Rs.3,406/- as unexplained expenditure u/s 69C of the I.T. Act, 1961. 5. It is therefore prayed that addition made by the Assessing Officer and confirmed by CIT(A) may please be deleted ... written submission. The Ld. AR of the assessee submits that Assessing Officer also made addition of commission income @ 0.5% on LTCG for making against unexplained expenditure, which is also liable to be deleted. ITA Nos.552 & 882/SRT/2024 (A.Y.11-12) Rambilash R Jajoo & Sunita Jajoo 4. On the other hand, Ld. Senior Departmental

Rambilash Rajaram Jajoo, Surat vs. Income Tax Officer Ward-2(2)(4), Surat

ITA 552/SRT/2024[2011-12]Status: DisposedITAT Surat10 Feb 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) Rambilash Rajaram Jajoo (Physical Court Hearing) 429-432, Golden Point, Falsawadi, Ring Road, Surat City, Surat-395 002 [Pan : Aampj 0040 K] अपीलार्थी/Appellant Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 प्रत्यर्थी / Respondent आयकर अपील सं./Ita No. 882/Srt/2024 (Ay 2011-12) Sunita Jajoo 429-432, Golden Point, Near Bsnl Office, Falsawadi, Ring Road, Surat-395 002 [Pan: Aampj 0040 K] बनाम Vs Income Tax Officer, Ward- 2(2)(4), Aaykar Bhawan, Majura Gate, Opp. New Civil Hospital, Surat-395 001 अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से /Assessee By Ms. Richa Toshniwal. Ca राजस्व की ओर से /Revenue By Shri Minal Kamble, Sr. Dr सुनवाई की तारीख/Date Of Hearing 23.01.2025 उद्घोषणा की तारीख/Date Of Pronouncement 10.02.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeals By Separate Assessee Are Directed Against The Separate Orders Of Addl/Jcit(A)-7, Kolkata/National Faceless Appeal Centre, Delhi [For Short To As "Nfac/Ld.Cit(A)] Dated 21.03.2024 & 21.04.2023 For Same

Section 143(3)Section 147Section 148Section 254(1)Section 68Section 69C

subject, the learned CIT(A) has erred in confirming action of Assessing Office in making addition of Rs.3,406/- as unexplained expenditure u/s 69C of the I.T. Act, 1961. 5. It is therefore prayed that addition made by the Assessing Officer and confirmed by CIT(A) may please be deleted ... written submission. The Ld. AR of the assessee submits that Assessing Officer also made addition of commission income @ 0.5% on LTCG for making against unexplained expenditure, which is also liable to be deleted. 4. On the other hand, Ld. Senior Departmental Representative (Ld. CIT-DR) for the Revenue supported

Deputy Commissioner of Income Tax Central Circle -1(2), Nagpur vs. Vidarbha Infotech Private Limited, Nagpur

In the result, appeal by the Revenue is dismissed

ITA 76/NAG/2024[2016-17]Status: DisposedITAT Nagpur10 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke
Section 133(6)Section 133ASection 139(1)Section 143(3)Section 147Section 148Section 250Section 263Section 44ASection 69C

circumstances of the case & in law, the Ld. CIT(A) has erred in deleting the addition of Rs.7,50,00,000/- on account of Unexplained Expenditure u/s 69C of the I.T. Act, 1961, without appreciating the fact that the addition of Rs.7,50,00,000/- made ... addition of ` 7.50 crore made by the Assessing Officer under section 69C of the Income Tax Act, 1961 ("the Act") on account of unexplained expenditure. 4. Facts in Brief:– The assessee is a company. On 26/12/2019, a survey under section 133A of the Act was conducted by the Investigation Wing

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 877/PUN/2024[2019-2020]Status: DisposedITAT Pune07 Feb 2025AY 2019-2020

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

Section 132Section 143(2)Section 153A

held that the First Appellate Authority erred in sustaining the addition of Rs 6,00,000/- on account of unexplained expenditure under section 69C of the Act which was made by the Learned Assessing Officer [Ld. AO) without considering the reply filed by the Appellant. The addition so made ... provisions and scheme of the Act, it be held that the addition sustained by the First Appellate Authority on account of unexplained expenditure under section 69C of the Act is unwanted, unjustified, and contrary to the provisions and scheme of the Act. The addition so made be deleted. The Appellant

Shree Balaji Realty, Pune vs. Income Tax, Central Circle 2(3), Pune

In the result, appeals for

ITA 876/PUN/2024[2018-19]Status: DisposedITAT Pune07 Feb 2025AY 2018-19

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

Section 132Section 143(2)Section 153A

held that the First Appellate Authority erred in sustaining the addition of Rs 6,00,000/- on account of unexplained expenditure under section 69C of the Act which was made by the Learned Assessing Officer (Ld. AO) without considering the reply filed by the Appellant. The addition so made ... provisions and scheme of the Act, it be held that the addition sustained by the First Appellate Authority on account of unexplained expenditure under section 69C of the Act is unwanted, unjustified, and contrary to the provisions and scheme of the Act. The addition so made be deleted. The Appellant