Section 69A of the Income Tax Act

Income-tax Act, 2025: s.104

Section 69A of the Income-tax Act, 1961 corresponds to section 104 (Unexplained asset) of the Income-tax Act, 2025.

Read section 104 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 69A is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 of the 15,297 judgments on BharatTax that turn on this section.

Leading authorities on Section 69A

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Continental Warehousing Corporation (Nhava Sheva) Ltd.
374 ITR 645 · 2015 · High Court
1,823
citing judgments

In Section 153A proceedings, the scope of assessment extends to abated proceedings, enabling an assessee to raise fresh legal claims that could have been made in regular assessment proceedings.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

K.P. Varghese v. ITO
131 ITR 597 · 1981 · Supreme Court
989
citing judgments

An addition to income cannot be made merely on the basis of a difference in valuation of assets or a Valuation Officer's report without establishing actual understatement of consideration or the source of unexplained funds through proper enquiry. The Assessing Officer must conduct proper enquiry and satisfy the conditions for making such additions.

PCIT v. Best Infrastructure (India) (P.) Ltd.
397 ITR 82 · 2017 · High Court
786
citing judgments

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

Pullangode Rubber Produce Co. Ltd. v. State of Kerala
91 ITR 18 · 1973 · Supreme Court
666
citing judgments

Admissions, whether made through entries in account books or statements, are important pieces of evidence but are not conclusive. An assessee has the right to demonstrate that an admission made by them is incorrect or can be retracted.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

Judgments on Section 69A

R B Diamond House, Jalgaon vs. Pne-C-1, Range -25, Circle -1, Office of the Commissioner of Income Tax- Jalgaon

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

ITA 1948/PUN/2025[2016-17]Status: DisposedITAT Pune19 Dec 2025AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1948/Pun/2025 निर्धारण वर्ष / Assessment Year : 2016-17 R B Diamond House, Opposite Manohar Sarees, Baliram Peth, Jalgaon-425001 Pan : Aaifr9130Q Vs. Pne-C-1, Range-25, Circle-1, Cit, Jalgaon अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sanjay T. Tupe Department By : Smt. Indira R. Adakil Date Of Hearing : 04-12-2025 Date Of Pronouncement : 19-12-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 10.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To Assessment Year (“Ay”) 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal :- "Ground No. 1: Ex-Parte Order Bad In Law 1. On The Facts & Circumstances Of The Case & In Law, The Ex Parte Order Passed By Cit(A)/ Nafc Is Bad In Law & Violates Principles Of Natural Justice. This Has Lead To A Denial Of Effective Opportunity For A Hearing. Ground No. 2: Violation Of Section 250(6) 2. On The Facts & Circumstances Of The Case & In Law, Cit(A)/ Nafc Failed To Comply With Section 250(6), Requiring Reasoned Findings On Each Ground Of Appeal. Ground No. 3: Non-Response Of Notices Due To Medical Issue 3. On The Facts & Circumstances Of The Case & In Law, Hearing Notices Were Not Responded To Due To The Illness Of Ms. Rupal Bagrecha Who Is Taking Care Of Accounting, All Income Tax & Other Statutory Compliances. Her E-Mail Id Rupalbagrecha21@Gmail.Com Is Registered On The Income Tax Portal. She Was Suffering From Severe Symptoms Of Epilepsy & Undergoing Medical Investigation From February 2025 Onwards, Preventing Timely Communication Of Notices To The Tax Consultant, Constituting Reasonable & Sufficient Cause For Non-Response.

For Appellant: Shri Sanjay T. TupeFor Respondent: Smt. Indira R. Adakil
Section 250(6)Section 69A