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Reconciled Third-Party Ledger Differences Cannot Be Taxed Under Section 69A: Mumbai ITAT

Case Law Details

TaxGuru Citation
2026 taxguru.in 11970
Case Name
Jeeten Jayshukhlal Mehta Vs DCIT (ITAT Mumbai Bench)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2023-24
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Jeeten Jayshukhlal Mehta Vs DCIT (ITAT Mumbai Bench)

Ledger Mismatch Is Not Unexplained Money: ITAT Deletes ₹27.39 Lakh Addition but Rejects Unsupported Travel Claim

Summary: In Jeeten Jayshukhlal Mehta v. DCIT, ITA No. 2997/Mum/2026, decided on 27 August 2026, the Mumbai Bench of the Income Tax Appellate Tribunal examined whether differences appearing in third-party ledgers could justify an addition of ₹27,39,649 u/s 69A, as well as whether travelling expenditure of ₹4,45,803 was allowable as a business deduction. The Tribunal partly allowed the assessee’s appeal by deleting the addition u/s 69A but sustained the travelling-expense disallowance.

Relevant Facts

The assessee, a resident individual, filed his return for AY 2023-24, declaring total income of ₹3,15,73,180. The return was selected for scrutiny on several grounds, including profits reported under specified business codes, disallowance u/s 40(a)(ia), high-value loan transactions outside banking channels & high income not corresponding with the assets & liabilities schedule.

During scrutiny, the AO issued notices u/s 142(1) & 143(2), seeking details & supporting evidence. On examining purchases from Zim Integrated Shipping Services (India) Ltd., the AO noticed that the assessee’s purchase register reflected purchases of ₹9,64,998, whereas departmental information showed purchases of ₹26,39,034. The supplier’s ledger allegedly reflected payments of ₹1,19,04,219, while the assessee maintained that actual payments were only ₹1,06,52,328.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,254

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