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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 1083 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 201 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


ITAT Deletes Addition Based on Builder’s Disclosure; Finds Cash Payment Reasonable

November 8, 2025 2013 Views 0 comment Print

AO had added ₹11,38,000/- towards the amount paid to a builder — ₹8,00,000/- by cheque & ₹3,38,000/- in cash — treating it as unexplained. CIT(A)/NFAC upheld the addition on the ground that Assessee failed to substantiate the source of payment.

Addition Based Solely on Third-Party Statement Without Cross-Examination Quashed

November 7, 2025 2082 Views 0 comment Print

ITAT Ahmedabad held that an addition under Section 69 based only on an untested third-party statement, without cross-examination, violates natural justice. The ₹60 lakh on-money allegation was deleted.

Assessment on Deceased Person Annulled: ITAT Quashes ₹1.73 Cr Addition

November 7, 2025 4506 Views 0 comment Print

ITAT Ahmedabad upheld annulment of a ₹1.73 crore assessment, ruling that Section 148 notice was issued in name of a person who had died four years earlier. Tribunal affirmed that proceedings against a deceased person are a fatal jurisdictional defect and void ab initio.

Voluntary Survey Disclosures Do Not Attract Section 115BBE: ITAT Jaipur

November 6, 2025 621 Views 0 comment Print

ITAT Jaipur held that Rs. 8.9 lakh surrendered during a survey and included in books as business income cannot be taxed under section 69C or 115BBE of Income Tax Act.

AO’s acceptance of excess stock as business income upheld- 115BBE not attracted

November 6, 2025 462 Views 0 comment Print

The Tribunal held that the Assessing Officer rightly accepted excess stock and cash disclosed during survey as business income after enquiry. Section 115BBE was not applicable, and PCIT’s revision under Section 263 was invalid.

Entire Purchase Can’t Be Disallowed as Bogus When Sales Are Accepted: ITAT Chennai

November 4, 2025 1545 Views 0 comment Print

ITAT Chennai held that when sales are accepted and supported by records, entire purchases cannot be treated as bogus merely because suppliers were untraceable. Addition restricted to 12.5% as profit element.

On-Money Addition Reduced by 70% as Only Profit Element is Taxable: ITAT Rajkot

November 4, 2025 489 Views 0 comment Print

The ITAT Rajkot significantly reduced an addition made under Section 69, ruling that in cases of alleged “on-money” payments found during a search, only the embedded profit component is taxable. Following the Gujarat High Court precedent, the Tribunal restricted the unexplained investment addition of Rs.1.25 lakh to just 30% (Rs.37,500).

PCIT Empowered to Revise Incomplete Assessments—Failure to Tax Entire Survey Disclosure Held Prejudicial to Revenue

November 4, 2025 291 Views 0 comment Print

Pune ITAT dismissed a firm’s appeal, confirming the PCIT’s order to tax Rs 19.44 lakh in unexplained cash and stock found in a survey under the stringent Section 115BBE.

ITAT Pune Deletes ₹16.9 Lakh Section 69 Addition – Transaction Belonged to Earlier Year

November 4, 2025 858 Views 0 comment Print

The Pune ITAT allowed the assessee’s appeal, confirming that the alleged unexplained investment transaction occurred in the earlier financial year. The ruling emphasizes the Assessing Officer’s duty to verify the correct assessment year before invoking Section 69, as liability must attach to the right period.

Addition towards bogus accommodation entry of LTCG deleted as primary onus discharged

November 3, 2025 441 Views 0 comment Print

ITAT Mumbai held that addition for providing accommodation entries of bogus LTCG under section 68 of the Income Tax Act is rightly deleted by CIT(A) since assessee has duly discharged the primary onus. Accordingly, appeal of revenue dismissed.

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