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Section 69

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ITAT Deletes On-Money Addition as Unsigned Agreement & Third-Party Records Lacked Evidence

Income Tax : Smt. Ranjana Kumari/Kalta Vs DCIT/ACIT (Central) (ITAT Chandigarh) The appeals involved three assessees belonging to the Kalta Gro...

June 30, 2026 330 Views 0 comment Print

FAQs on Penalty provisions under Income Tax Act, 1961

Income Tax : This guide explains when penalties can be imposed under various provisions of the Income-tax Act, 1961. It also outlines the appli...

June 22, 2026 5895 Views 0 comment Print

Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 1038 Views 0 comment Print

Unexplained Income: Taxation under Sections 68 to 69D of Income-tax Act

Income Tax : Income without satisfactory explanation is taxed at a special high rate under Section 115BBE. The provisions place strict liabilit...

April 9, 2026 1080 Views 1 comment Print

A Doctrinal Analysis of Deemed Income under Sections 68–69D of Income Tax Act, 1961

Income Tax : A doctrinal analysis of unexplained cash credits, investments, and expenditure under Sections 68–69D. Explains burden of proof a...

February 25, 2026 1173 Views 0 comment Print


Latest Judiciary


Section 69 Addition Unsustainable as Joint Ownership & Foreign Investment Source Established: ITAT Mumbai

Income Tax : ITAT Mumbai deleted a Section 69 addition after finding documentary evidence established joint ownership, source of funds, and ear...

July 5, 2026 192 Views 0 comment Print

Sale Deed Alone Cannot Justify Tax Addition as It Is Not Incriminating Material: ITAT Delhi

Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...

July 4, 2026 288 Views 0 comment Print

ITAT Delhi Restricts Section 69 Addition as Unsupported Extrapolation Lacked Evidence

Income Tax : ITAT held that multiplying a seized figure without supporting evidence was unjustified and restricted the Section 69 addition to t...

July 3, 2026 279 Views 0 comment Print

ITAT Cancels Section 153C Proceedings as Amended Law Barred Jurisdiction

Income Tax : The Tribunal ruled that proceedings initiated under the old Section 153C framework after the Finance Act, 2021 amendments were leg...

June 29, 2026 312 Views 0 comment Print

Non-Mention of Sections 69 to 69D Cannot Defeat Unexplained Cash Addition: ITAT Hyderabad

Income Tax : Tribunal held that omission to mention the exact charging provision did not vitiate the assessment where unexplained cash and bull...

June 28, 2026 246 Views 0 comment Print


Common Satisfaction Note for Multiple AYs Invalid U/s 153C: ITAT Bangalore

March 12, 2026 696 Views 0 comment Print

The case addressed whether tax authorities can issue notices for multiple years based on one satisfaction note. The tribunal ruled that each assessment year requires an independent satisfaction linking seized material.

Depreciation disallowed as creation of goodwill in intra-group merger was colourable transaction

March 5, 2026 588 Views 0 comment Print

ITAT Pune held that creation of artificial intangible asset i.e. goodwill in intra-group merger is merely a colourable transaction out between the Holding Company and the subsidiary company. Accordingly, depreciation claimed thereon deserves to be disallowed.

Investment Cannot Be Treated as Income Merely for Alleged Section 13 Breach: ITAT Delhi

March 4, 2026 525 Views 0 comment Print

The Tribunal ruled that exemption under Sections 11 and 12 cannot be denied by aggregating separate shareholdings to invoke Section 13(2)(e). It held that no office bearer individually held substantial interest, making the addition unsustainable.

Rs. 50 Lakh LIC Investment Treated as Unexplained Due to Failure to Prove HUF Source

March 2, 2026 870 Views 0 comment Print

The Tribunal upheld addition under Section 69 as the assessee failed to establish that the LIC investment belonged to the HUF. Mere assertion of agricultural income without documentary evidence was held insufficient.

Section 153C Assessment Quashed Because Consolidated Satisfaction Note Lacked Year-Wise Incriminating Material

March 2, 2026 1449 Views 0 comment Print

ITAT Delhi held that recording a single satisfaction note for multiple assessment years violates Section 153C requirements. As no year-specific incriminating material was identified, the assessments were quashed along with the related penalty.

A Doctrinal Analysis of Deemed Income under Sections 68–69D of Income Tax Act, 1961

February 25, 2026 1173 Views 0 comment Print

A doctrinal analysis of unexplained cash credits, investments, and expenditure under Sections 68–69D. Explains burden of proof and strict taxation under Section 115BBE.

Section 69 Property Addition Deleted – Agreement vs Sale Deed Difference Not Sufficient Evidence: ITAT Ahmedabad

February 24, 2026 474 Views 0 comment Print

The Tribunal upheld deletion of addition made on alleged unexplained investment in property. It held that difference between initial agreement value and final sale deed, without evidence of extra payment, cannot justify addition under Section 69.

ITAT Ahmedabad Deletes Sec 69 Additions; NRI Property, Cash & Stamp Duty Explained with Bank Evidence After DRP Relief

February 24, 2026 519 Views 0 comment Print

ITAT Ahmedabad held that property payments were properly explained with bank records and affidavits. Additions under Section 69 for cash deposit and stamp duty were deleted.

ITAT Raipur Grants Relief Where PAN Status Mix-Up Led to Taxation as Partnership Firm

February 24, 2026 489 Views 0 comment Print

The ITAT relied on orders under section 148A(d) for subsequent years where reopening was dropped, holding the assessee to be a local authority. The earlier additions for unexplained investment and interest income were set aside.

Penny Stock LTCG Addition Deleted – Investigation Report Alone Not Sufficient Without Direct Evidence: ITAT Mumbai

February 21, 2026 1062 Views 0 comment Print

ITAT Mumbai deleted ₹6.15 lakh penny stock LTCG addition, holding investigation report and abnormal price rise insufficient without direct evidence linking assessee to accommodation entries.

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