ACIT Vs Radaan Media Works India Limited (ITAT Chennai)
Addition u/s 69C deleted – Director advances already recorded in books; survey statement alone insufficient – ITAT Chennai
In ACIT vs Radaan Media Works India Ltd. (A.Y. 2015-16), the AO made addition of ₹2.07 crore u/s 69C treating director withdrawals reflected in loose sheet “SARATH KUMAR SUSPENSE” as unexplained expenditure, mainly relying on statements recorded during survey and search proceedings.
The ITAT observed that the assessee produced ledger accounts, bank statements and financial records showing that the amounts were business-related advances to directors and were already recorded in books prior to search. The Tribunal held that survey statements alone have no evidentiary value without corroborative material, relying on CIT v. S. Khader Khan Son.
Since the AO failed to establish any expenditure outside books or undisclosed income, section 69C was held inapplicable. The Tribunal also rejected Revenue’s Rule 46A objection, noting that evidences were part of regular records. Accordingly, deletion of addition by CIT(A) was upheld and Revenue’s appeal was dismissed
FULL TEXT OF THE ORDER OF ITAT CHENNAI
The captioned appeal by the revenue is arising out of the order of the Ld. Commissioner of Income Tax (Appeals) Chennai-19, dated 09.05.2025 for AY 2015-16.
