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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 1077 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 183 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 285 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 276 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


No U/s 115BBE Tax Because Income Was Business Profit, Not Unexplained Money

December 20, 2025 1269 Views 0 comment Print

The ITAT held that unrecorded sales cannot be taxed in full under Section 69A. Only the profit element at a reasonable GP rate is assessable as business income.

Additions based on BUP IDs, internal identifiers and presumptive opening deposits are not sustainable

December 20, 2025 630 Views 0 comment Print

ITAT Mumbai held that additions made on substantive and protective basis merely on the strength of BUP IDs, internal identifiers, and presumptive opening deposits are unsustainable. Accordingly, appeal of revenue dismissed.

Seller’s Settlement Admission Can’t Implicate Buyer: On-Money Addition Deleted

December 19, 2025 657 Views 0 comment Print

ITAT held that on-money admitted by a seller before the Settlement Commission cannot be presumed against the purchaser without independent evidence. In absence of any seized material or proof of cash payment, the addition u/s 69 was deleted.

153C Assessment Remanded for Failure to Examine Jurisdictional Satisfaction

December 19, 2025 276 Views 0 comment Print

The case examined whether assessments under Section 153C were valid without proper recording of statutory satisfaction. The Court remanded the matter, holding that jurisdiction must be decided before examining additions on merits.

Appeal Delay Condoned Because Police Proceedings Are a Valid Reason for delay

December 19, 2025 228 Views 0 comment Print

The appeal was filed late due to ongoing police proceedings against the assessee. The Tribunal held this to be sufficient cause and restored the appeal for fresh consideration.

Presumptive Taxation Applied Because Business Receipts Can’t Be Fully Treated as Unexplained

December 19, 2025 315 Views 0 comment Print

The issue was whether entire cash deposits could be added as unexplained despite income being declared under section 44AD. The Tribunal held that presumptive taxation shields routine business deposits, though a reasonable lump-sum addition was justified where receipts were partly unsubstantiated.

Amended Section 115BBE Rate Not Applicable Retrospectively on Section 69A Addition

December 18, 2025 1827 Views 0 comment Print

The assessee claimed the firm had dissolved and deposits belonged to a partner. The Tribunal held that absence of documentary proof justified treating bank deposits as unexplained income.

Reassessment Quashed As AO issuing notice lacked Jurisdiction Over Non-Resident

December 18, 2025 1011 Views 0 comment Print

The tribunal examined whether reassessment could be initiated by an officer lacking jurisdiction over a non-resident assessee. It held that notices issued by an incorrect authority render the entire reassessment void.

Rs. 113.46 Crore Section 68 Addition Fails Due to Jurisdictional Defect

December 17, 2025 930 Views 0 comment Print

The issue was whether an Assessing Officer can travel beyond limited scrutiny without mandatory approval. The Tribunal held that such action violates binding CBDT Instructions and renders the assessment void from inception

Search Assessment Limited as Bank Valuation Found Insufficient Evidence

December 17, 2025 267 Views 0 comment Print

Delhi ITAT held that a bank’s valuation report obtained post-search is not incriminating material, restricting unexplained investment addition to a reasonable estimate.

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