“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

Reeta Devi, Banna Mau Lalganj Raebareli vs. Commissioner of Income Tax(Appeals) Income Tax Department, Raebareli

In the result, both the appeals are treated as allowed, for statistical purposes

ITA 439/LKW/2024[2015-16]Status: DisposedITAT Lucknow24 Jan 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Anadee Nath Misshra

For Appellant: NoneFor Respondent: Shri Sunil Kumar Rajwanshi, D.R

Section 133(6)Section 144Section 147Section 271(1)(c)Section 69ASection 69C

assessee under section 69A of the Act. 2.1 Moreover, the expenditure, totaling to Rs.8,41,179/- relating to various entities were also treated as unexplained expenditure and added the same also to the income of the assessee under section 69C of the Act. 3. The AO completed the assessment under

Kshama Sanjay Tripathi, Ahmedabad vs. The ITO, Ward-4(2)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 450/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2010-11

Bench: Dr. Brr Kumar & Ms Suchitra Kamblei.Ta. No.450/Ahd/2020 (Assessment Year: 2010-11) Kshama Sanjay Tripathi, Vs. The Income Tax Officer, 76, Super Bunglow, Ward-4(2)(2), Science City, Ahmedabad. Sola Road, Ahmedabad-380060. [Pan No.Afypt1577L] (Appellant) .. (Respondent) Appellant By : Shri Mehul K Patel, Ar Respondent By: Shri Rignesh Das, Sr. Dr 13.01.2025 Date Of Hearing Date Of Pronouncement 24.01.2025 O R D E R

For Appellant: Shri Mehul K Patel, ARFor Respondent: Shri Rignesh Das, Sr. DR

Section 144Section 148

facts and in law, the learned CIT (A) has grievously erred in enhancing the assessment by making addition of Rs.2,10,000/- towards unexplained expenditure without issuing notice of enhancement as required by law. 3. The appellant craves leave to add, alter, and amend any ground of appeal. 3. Facts ... Rs.17,58,500/- made on account of cash deposits in the bank account but enhanced the addition by Rs.Rs.2,10,000/- being unexplained expenditure 4. Aggrieved by the order of the Ld. CIT(A), the Assessee filed appeal before the Tribunal. 5. Before us, the Ld. AR argued explaining

Integrated Gas Controls Technologies Private Limited, Hyderabad vs. Income Tax Officer, Ward-2(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 1172/HYD/2024[2018-19]Status: DisposedITAT Hyderabad24 Jan 2025AY 2018-19

Bench: Shri Vijay Pal Rao (Vice President), Shri Manjunatha G. (Accountant Member)

For Appellant: Shri T.Chaitanya Kumar, ARFor Respondent: Shri Srinath Sadanala, DR

Section 194JSection 69C

file bills for expenses and agreement if any with the party. Therefore, made addition of Rs.31,85,557/- u/s 69C of the Act as unexplained expenditure. Similarly, the Assessing Officer noticed that the assessee has paid Rs.3,00,000/- to M/s Karamchand Linganna Komireddy. The assessee has also paid Rs.2 ... file relevant evidences in support of the above three payments. Therefore, made additions of Rs.14,54,144/- u/s 69C of the Act as unexplained expenditure and brought to tax under the provisions of 115BBE of the Act. 3. Being aggrieved by the assessment order, the assessee preferred an appeal before

Assistant Commissioner of Income Tax, Chennai vs. A S Cargo Movers Private Limited, Chennai

In the result, the appeal of the Revenue and assessee are decided as under:-

ITA 1796/CHNY/2024[2017-18]Status: DisposedITAT Chennai24 Jan 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1688 /Chny/2024, Assessment Years: 2015-16 आयकर अपील सं./Ita No.1796 /Chny/2024, Assessment Years: 2017-18 Assistant Commissioner Of Income A.S.Cargo Movers Private Limited, Tax, New No.173, Old No.103, 9Th Floor B Corporate Circle-1(1), Block, Navins Presidium, Chennai. Nelson Manickam Road, Aminjikarai, Chennai-600 029. [Pan: Aaaca7739D] आयकर अपील सं./Co No.56 /Chny/2024 (Ita No.1688/Chny/2024) निर्ाारण वर्ा /Assessment Year: 2015-16 A.S.Cargo Movers Private Limited, Assistant Commissioner Of Income New No.173, Old No.103, 9Th Floor B Tax, Block, Navins Presidium, Corporate Circle-1(1), Nelson Manickam Road, Chennai. Aminjikarai, Chennai-600 029. [Pan: Aaaca7739D] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri N.Quadir Hoseyn, Advocate & Dr.L.Natarajan, Ca. प्रत्यर्थी की ओर से /Revenue By : Shri K.N.Dhandapani, Cit सुिवाई की तारीख/Date Of Hearing : 04.12.2024 घोर्णा की तारीख /Date Of Pronouncement : 24.01.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri N.Quadir Hoseyn, Advocate &For Respondent: Shri K.N.Dhandapani, CIT

Section 250

next issue raised by the Revenue is regarding an addition of Rs. 15 Crs made by the Ld. AO on account of unexplained expenditure u/s 69. The Ld. DR submitted that the Ld. AO has discussed the issue on page 10 to 19 of his order. The Ld. AO noted ... that the entire transaction was a sham transaction done to evade taxes. He proceeded to add Rs. 15 Crs u/s 69 as an unexplained expenditure. Page - 14 - of 17 ITA No.1688, 1796 & CO-56/Chny/2024 :- 15 -: 15.1 The Ld. DR submitted that the relief accorded

Assistant Commissioner of Income Tax, Corporate Circle 1(1), Chennai vs. A S Cargo Movers Private Limited, Chennai

In the result, the appeal of the Revenue and assessee are decided as under:-

ITA 1688/CHNY/2024[2015-16]Status: DisposedITAT Chennai24 Jan 2025AY 2015-16

For Appellant: Shri N.Quadir Hoseyn, Advocate &For Respondent: Shri K.N.Dhandapani, CIT

Section 250

ACIT CC-6(1), Mumbai, Bkc vs. Sharad Nagnath Rajbhoj, Pune

In the result, the appeal by the Revenue is dismissed

ITA 5661/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jan 2025AY 2021-22

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailacit, Central Circle – 6(1), Room No.445, 4Th Floor, Bkc, Mumbai – 400051 ............... Appellant Pan : Abapr6416N V/S Sharad Nagnath Rajbhoj, 502 Dsk Haiyali Phase-Ii, ……………… Respondent Modi Baug, Shivaji Nagar, Pune - 411005 Assessee By : Shri Rashmikant Modi Ms. Ketki Rajshirke Revenue By : Shri Dr. Kishor Dhule, Cit-Dr

For Appellant: Shri Rashmikant ModiFor Respondent: Shri Dr. Kishor Dhule, CIT-DR

Section 132Section 132(4)Section 147Section 148Section 250Section 69ASection 69C

other as both the evidence shows the identical amount paid by the assessee. Accordingly, the amount of Rs.1,25,00,000 was treated as unexplained expenditure as per the provisions of section 69C of the Act and added to the total income of the assessee. Further, on the basis

Sanjaybhai Arjunbhai Patel, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-1, Surat

ITA 79/SRT/2023[2018-19]Status: DisposedITAT Surat23 Jan 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth

Section 254(1)Section 292C

restricting the addition to Rs.50,12,212/- as against addition of Rs. 1,01,57,149/- made by the AO on account of unexplained expenditure in renovation of house despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings ... Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in making addition of Rs.50,12,212/- on account o: alleged unexplained expenditure for house renovation. 5. On the facts and in the circumstances of the case as well as law on the subject the learned commissioner

Assistant Commissioner of Income Tax, Central Circle - 1, Surat vs. Shri Sanjaybhai Arjunbhai Patel, Surat

In the result, the ground No

ITA 211/SRT/2023[2018-19]Status: DisposedITAT Surat23 Jan 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth

Section 254(1)Section 292C

Mr. Rangal Sathis Kumar, Chennai vs. ITO, Ncw-3(3), Chennai

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

ITA 2949/CHNY/2024[2017-18]Status: DisposedITAT Chennai23 Jan 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2949/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Mr. Rangan Sathis Kumar, Vs. The Income Tax Officer, No. 6, 4Th Cross Street, Ellaiamman Non Corporate Ward 3(3), Colony Vellala, Teynampet, Chennai. Chennai 600 086. [Pan:Bmvps9901E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, F.C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 22.01.2025 घोषणा की तारीख /Date Of Pronouncement : 23.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 81 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Assessee Are Bonafide, Which Really

For Appellant: Shri b. Ramakrishnan, F.C.AFor Respondent: Ms. R. Anita, Addl. CIT

Section 154Section 69C

extent of ₹.90,50,998/- and as the assessee failed to substantiate the source for the above payments made, the same were treated as unexplained expenditure under section 69C of the Income Tax 3 I.T.A. No.2949/Chny/24 Act, 1961 [“Act” in short] and added to the returned income of the assessee

Smt. Usha Satish Salvi, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle

In the result, the appeals of the assessee for all the three years

ITA 4239/MUM/2023[2012-13]Status: DisposedITAT Mumbai23 Jan 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Satish ModiFor Respondent: Mr. Ankush Kapoor, CIT-DR

Section 132Section 143(3)Section 153ASection 153CSection 153DSection 69C

right in bringing the unaccounted cash expenditure incurred for the movie, for which the appellant was involved in the capacity as producer, as unexplained expenditure u/s 69C of the Act." 11.2 Further, the assessee contended that actual cash expenditure mentioned in the loose papers was only of Rs.1

Smt. Usha Satish Salvi, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeals of the assessee for all the three years

ITA 4238/MUM/2023[2014-15]Status: DisposedITAT Mumbai23 Jan 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Satish ModiFor Respondent: 06/11/2024

Section 132Section 143(3)Section 153C

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP

Smt. Usha Satish Salvi, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

In the result, the appeals of the assessee for all the three years

ITA 4237/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Jan 2025AY 2013-2014

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Appellant: Mr. Satish ModiFor Respondent: 06/11/2024

Section 132Section 143(3)Section 153C

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP

Deputy Commissioner of Income Tax, Circle-Shillong, Shillong vs. Dhar Construction Company, Shillong

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

ITA 39/GTY/2024[2018-19]Status: DisposedITAT Guwahati22 Jan 2025AY 2018-19

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 194CSection 250Section 69C

appeal: “1) For that, the Ld. CIT(A) has erred in deleting an addition of Rs.2,97,16,776/- made by the AO as unexplained expenditure u/s 69C of the Income Tax Act although no supporting bills for such payments made u/s 194C to non-filers were furnished before ... expenditure and he returned a finding that the expenditure was not authenticated by vouchers and consequently, he added the said expenditure as unexplained expenditure under Section 69C. We are in agreement with the observations and findings of the Commissioner of Income-tax (Appeals) as well as that of the Income

Duraiswamy Chinnadurai, Coimbatore vs. ITO, Ncw-4(4), Coimbatore

In the result, the appeal is partly allowed

ITA 1782/CHNY/2024[2013-14]Status: DisposedITAT Chennai22 Jan 2025AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1782 /Chny/2024 निर्ाारण वर्ा /Assessment Years: 2013-14 Duraiswamy Chinnadurai, Income Tax Officer, No.146, N.G.N.Street, Non Corp, Ward-4(4), New Siddhapudur, Coimbatore Coimbatore. [Pan: Acppc1349B] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri S.Ramachandran, Ca प्रत्यर्थी की ओर से /Revenue By : Ms.Sheila Parthasarthy, Addl.Cit सुिवाई की तारीख/Date Of Hearing : 02.12.2024 घोर्णा की तारीख /Date Of Pronouncement : 22.01.2025 आदेश / O R D E R Per Amitabh Shukla, A.M : This Appeal Is Filed Against The Order Bearing Din & Order No.Itba/Nfac/S/250/2024-25/1064762387(1) Dated 09.05.2024 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), National Faceless Appeal Center[Nfac], Delhi, For The Assessment Years 2013- 14. Through The Aforesaid Appeal The Assesse Has Challenged Order U/S 250 Dated 09.05.2024 Passed By Nfac, Delhi. 2.0 The Assessee Has Raised Altogether Seven Grounds Of Appeal, Of Which Grounds 1 To 4 Are Legal Grounds & Grounds 5 To 7 On Merits.

For Appellant: Shri S.Ramachandran, CAFor Respondent: Ms.Sheila Parthasarthy, Addl.CIT

Section 132Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69ASection 69C

lakhs and Rs. 42 lakhs treating assessee’s share of investment as unexplained u/s 69A r.w. 115BBE, Rs.25 lakhs and Rs.8.33 lakhs as an unexplained expenditure u/s 69C, r.w. 115BBE. While making the impugned additions the Ld. AO recorded in para 5.3 of his order that “… the reply given

M/S. Rukmani Engineering Works, (Now Rukmani Infra Projects Pvt. Ltd., Odisha vs. The Dy. CIT- Circle- Korba, Korba(Cg)

In the result, appeal filed by the assessee firm being devoid and bereft of any merit is dismissed in terms of our aforesaid observations

ITA 81/RPR/2014[2008-09]Status: DisposedITAT Raipur21 Jan 2025AY 2008-09

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.81/Rpr/2014 "नधा"रण वष" / Assessment Year : 2008-09 M/S. Rukmani Engineering Works (Now Rukmani Infra Projects Pvt. Ltd.) Mig-384, Svbp Nagar, Jamnipali, Korba (C.G.) Pan: Aaifr4667G

For Appellant: NoneFor Respondent: Smt. Anubhaa Tah Goel, Sr. DR

Section 143Section 251Section 40

Rs.33, 55,197/-, towards suppressed profit, of Rs.9, 00,000/- towards capital introduction leading to concealed income Rs.4, 14,975/- on account of unexplained expenditure and has up hold penalty of 100% on income alleged to have escaped amounting to Rs. 1400000/- which is excessive illegal and appeared to faulty ... expenses. radiography charges, etc. for non-deduction or short deduction of tax at source and addition of Rs. 24,49,653/- on account of unexplained expenditure was confirmed by the 1st Appellate Authority. So far as addition of Rs.57,58,944/- is concerned, no inaccurate particulars were filed

Deputy Commissioner of Income Tax, Central Circel-2(1), Nagpur vs. M/S. Metrocity Homes, Nagpur

Appeals are allowed

ITA 165/NAG/2023[2019-20]Status: DisposedITAT Nagpur21 Jan 2025AY 2019-20

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

For Appellant: Shri Suren Duragkar a/w Ms. Hemmani DuragkarFor Respondent: Shri Sandipkumar Salunke

Section 132Section 139(1)Section 143(3)Section 153CSection 69ASection 69C

after making following additions:- 1 Unexplained money u/s 69A 98,18,540 2 Unexplained money u/s 69A 31,64,450 3 Unexplained expenditure u/s 69C 1,38,850 4 Unexplained money u/s 69A 64,03,400 The assessee being unsuccessful before the Assessing Officer, challenged the assessment order passed

Deputy Commissioner of Income Tax, Central Circel-2(1), Nagpur vs. M/S. Metrocity Homes, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 164/NAG/2023[2017-18]Status: DisposedITAT Nagpur21 Jan 2025AY 2017-18

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

For Appellant: Shri Suren Duragkar a/wFor Respondent: Shri Sandipkumar Salunke

Section 132Section 153C

Unexplained money u/s 69A ` 22,50,000/- 7 Unexplained money u/s 69A ` 3,53,000/- 8 Unexplained money u/s 69A ` 26,00,000/- 9 Unexplained Expenditure u/s 69C ` 10,00,000/- The assessee being unsuccessful before the Assessing Officer, challenged the assessment order passed by the Assessing Officer by filing ... Unexplained money u/s 69A ` 71,93,666/- 6 Unexplained money u/s 69A ` 22,50,000/- 7 Unexplained money u/s 69A ` 26,00,000/- 8 Unexplained Expenditure u/s 69C ` 10,00,000/- 4. On appeal, the assessee, before the learned CIT(A), has made elaborate submissions which were reproduced

Assistant Comissioner Central Circle 1(3), Nagpur vs. M/S Shrigopal Rameshkumar Sales Pvt. Ltd, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 135/NAG/2018[2015-2016]Status: DisposedITAT Nagpur21 Jan 2025AY 2015-2016

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

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke

Section 132Section 132(1)Section 139Section 69C

case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.37,47,574/- made by the AO being unexplained expenditure u/s 69C of the I.T. Act by accepting the explanation that the same are reflected in the books without appreciating the fact that the assessee ... facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.37,47,574/- being unexplained expenditure u/s 69C, recoveries from farmers of Rs.33,26,574/-, sale of cotton seed & bags of Rs.4,58,000/- and Rs. 20,800/- respectively as they

The DCIT, Central Circle-2(4), Ahmedabad vs. J.A . Infracon Pvt. Ltd., Ahmedabad

ITA 166/AHD/2021[2012-13]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2012-13

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 133(6)Section 143(1)Section 143(3)Section 69C

unexplained income of the assessee and also treated the commission expenses calculated at 2.5% on the above amount of Rs.26,25,000/- as unexplained expenditure u/s. 69C of the Act and demanded tax thereon as follows: Amount of Sr. Name of the Number Amount of share Total share No. applicant

Dy.Commissioner of Income Tax, Central Circle-1, Aurangabad vs. Shri. Balaji Ramchandra Ande, Latur

In the result, appeal of the Revenue dismissed

ITA 625/PUN/2024[2018-19]Status: DisposedITAT Pune21 Jan 2025AY 2018-19

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Shri Sharad A Shah And Shri Rohit S TapadiyaFor Respondent: Shri Ramnath P Murkunde

Section 115BSection 131Section 133ASection 143(2)Section 68Section 69ASection 69BSection 69C

amount of Rs.1,27,03,129/- on account of 3 ITA.No.625/PUN./2024 labour payments, all totaling to Rs.1,95,45,687/- as unexplained expenditure. He, therefore, asked the assessee to explain as to why the unexplained expenditure of Rs.1,95,45,687/- should not be treated as deemed income ... satisfactorily explained, then the value of such investments and money, or value of articles not recorded in the books of account or the unexplained expenditure may be deemed to be the income of such assessee. It follows that the moment a satisfactory explanation is given about such nature and source