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Section 69

Latest Articles


The IT Ecosystem of India Is Non-Democratic: A Critical Legal Analysis

Income Tax : Explains the centralization of digital platforms, surveillance powers, and opaque governance. Key takeaway: citizens have limited ...

November 22, 2025 216 Views 0 comment Print

FAQs on Penalty provisions under Income Tax Act, 1961

Income Tax : Detailed overview of penalties under various sections of the Income Tax Act, covering defaults in tax payment, reporting, document...

October 30, 2025 4584 Views 0 comment Print

Arrest under GST: Law, Limitations and Constitutional Safeguards

Goods and Services Tax : GST arrest power under Section 69 is limited to grave offenses (evasion > ₹2 crore, or repeat fraud), requiring reasons to belie...

October 28, 2025 705 Views 0 comment Print

Unexplained Income Provisions: Sections 68, 69, 69A, 69B, 69C & 69D

Income Tax : An overview of Sections 68-69D of India's Income-tax Act, which empower tax authorities to assess unaccounted income from unexplai...

September 24, 2025 1077 Views 0 comment Print

Analysis of Undisclosed Incomes under Sections 68 to 69D of Income Tax Act, 1961

Income Tax : A Comprehensive Analysis of Undisclosed Incomes under Sections 68 to 69D of the Income-tax Act, 1961, Taxation of these Incomes Un...

June 20, 2025 6309 Views 2 comments Print


Latest Judiciary


ITAT Confirms FTC Allowance Under Section 90/91 for Investments Held Abroad

Income Tax : ITAT upheld deletion of ₹3.31 crore addition under Section 69, noting full disclosure of foreign assets and sufficient income. R...

December 12, 2025 75 Views 0 comment Print

ITAT Deletes Section 69 Additions Over Unsupported On-Money Claims

Income Tax : ITAT Mumbai deleted Section 69 additions as the Revenue relied only on uncorroborated statements and pen-drive data from third par...

December 12, 2025 42 Views 0 comment Print

CIT(A) Mistaken on VSVS Leads ITAT to Remand Quantum Appeal

Income Tax : The Tribunal held that CIT(A) misinterpreted a VSVS 2020 declaration for penalty as covering quantum, dismissing the appeal withou...

December 10, 2025 78 Views 0 comment Print

Tribunal Orders Fresh Probe on Rs. 5.24 Cr Land Addition Over 8-km Claim

Income Tax : ITAT Agra held that additional evidence proving the land’s distance from municipal limits is crucial for reassessment under Sect...

December 10, 2025 213 Views 0 comment Print

Delhi HC Upholds Prosecution in ₹348 Crore Tax Evasion Case

Income Tax : Delhi High Court ruled that prosecution under Income Tax Act Sections 276C and 278E can proceed when evaded tax exceeds Rs.25 cror...

December 10, 2025 1545 Views 0 comment Print


CIT(A) cannot treat addition made by AO U/s. 69C as made U/s. 69B

April 24, 2022 3309 Views 0 comment Print

M/s Toffee Agricultural Farms Pvt. Ltd. Vs ITO (ITAT Delhi) Coming to the question regarding action of the learned CIT (Appeals) to treat the reference u/s 142 for the purpose of Section 69B, I find merit into the contention of the assessee that there is no power conferred upon the learned CIT(Appeals) to assess a […]

No addition for unsecured loan received if Source & Nature explained

February 21, 2022 3471 Views 0 comment Print

ITO Vs Sandeep S. Dagaria (ITAT Mumbai) ITAT notices that Assessing Officer has merely proceeded to make addition of Rs.7,00,000/- unsecured loans merely because the Rajat Group of Companies involved in the transaction of bogus purchases and rejected the evidences submitted before him i.e. assessee has submitted the confirmation balance and the transactions were only […]

Section 69 Addition justified if no satisfactory explanation provided

February 17, 2022 495 Views 0 comment Print

Ashok Kumar Yadav Vs ITO (ITAT Delhi) Ld. Counsel for assessee contended that AO has wrongly made addition of the cash deposit in the bank account u/s 69 of the Act. We do not agree with the contention of the Ld. Counsel for the assessee because assessee made a cash deposit of the impugned amount […]

Scheme of tax treaties limits the rights of taxation either to residence or to source jurisdiction

December 15, 2021 2997 Views 1 comment Print

ITO Vs Rajeev Suresh Ghai (ITAT Mumbai) It is always useful to bear in mind the fact that, on the first principles, the trigger for taxation of an income in a source jurisdiction is either the economic activity or the linkage of an income with that jurisdiction, and that in the absence of such a […]

Bogus purchases: Entire purchases cannot be taxed

December 7, 2021 3909 Views 0 comment Print

United Waterproofing Corporation Vs ITO (ITAT Mumbai) We note that Ld. CIT(A) has enhanced the addition on account of bogus purchases to 100% of the bogus purchases as against 12.5% applied by the AO. The only reason given by the Ld. CIT(A) is that the assessee has failed to prove the genuineness of purchases and […]

No addition of unaccounted investment if transactions were via Banking Channels

December 2, 2021 1317 Views 0 comment Print

Addition on account of investment made from undisclosed sources was deleted as as all transactions were made through banking channels and AO had made the addition in question on assumption and presumption basis.

Section 69 not applies to transactions recorded in Books

October 13, 2021 17598 Views 0 comment Print

Once the transaction is found to be recorded in the regular books of account, provisions of section 69 do not apply and the CIT(A) had, therefore, rightly deleted the addition which calls for no interference.

Tax Treatment of cash credit

September 28, 2021 5265 Views 0 comment Print

As per section 68 of the Income Tax Act, any sum found credited in the books of a taxpayer, for which he does not explain the nature and source or the explanation provided by him is not satisfactory by the Assessing Officer is termed as ‘Cash Credit‘. Other provisions to be kept in mind with […]

HC upheld addition for cash payment for shares from unexplained Sources

September 5, 2021 738 Views 0 comment Print

Jaidayal Prannath Kapur Vs CIT (Madras High Court) The assessment for the Assessment Year under consideration, AY 2002-03, was reopened and notice under Section 148 of the Act was issued. From the findings recorded by the Assessing Officer in the Assessment Order, dated 19.12.2007, we find that, initially, the assessee did not extend full cooperation […]

Section 147 or 153C Assessment – Search from 3rd party premises – Unexplained Money addition under Section 69A

May 24, 2021 10176 Views 0 comment Print

ACIT Vs. K. S. Chawla & Sons (HUF) (ITAT Delhi) > HELD THAT:- In the present assessee’s case, search & seizure action u/s 132 of the Act was carried out on 15.10.2009 in the premises of Mr. Abhinav Arora and Mrs. Ranju Arora. Consequently, the Assessing Officer initiated reassessment proceedings u/s 147 of the Act […]

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