Section 69D of the Income Tax Act
Income-tax Act, 2025: s.106
Section 69D of the Income-tax Act, 1961 corresponds to section 106 (Amount borrowed or repaid through negotiable instrument, hundi, etc) of the Income-tax Act, 2025.
Read section 106 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 69D is CIT v. Rajasthan Financial Corporation (134 CTR 145), cited in 19 of the 184 judgments on BharatTax that turn on this section.
Leading authorities on Section 69D
An Assessing Officer's decision allowing a claim based on the assessee's detailed written explanation and inquiries made during assessment cannot be deemed erroneous simply because the order lacks elaborate discussion on the matter.
The Income Tax Appellate Tribunal (ITAT) considers arguments regarding additions made under Section 68 of the Income Tax Act, concerning loans and share application money, and arguments against such additions on merits. The tribunal's decisions often rely on the findings of lower authorities, including the Assessing Officer (AO) and Commissioner of Income Tax (Appeals) (CIT(A)).
An assessment order is not bad in law solely for failing to specify the section under which an addition is made, provided the addition is justified on merits.
