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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


Sundry creditors cannot be treated as bogus on mere personal belief & imagination of AO

September 7, 2022 3255 Views 0 comment Print

ACIT Vs Pradip Mullick (ITAT Kolkata) Assessee submitted that owing to business of manufacturing and sale of sweets and confectioneries, he has to regularly purchase different types of raw materials from different vendors for his day to day business requirement. The number of vendors are large as there are small vendors mostly supplying perishable item […]

Addition of unexplained investment unsustained based on high status/family tradition & Streedhan

August 22, 2022 1230 Views 0 comment Print

Held that factors like high status, family tradition, deduction on account of purity and deduction towards Streedhan should be considered before making addition on account of unexplained investment. Accordingly, addition deleted.

Section 263 cannot be invoked if assessment order is not erroneous but is prejudicial to Revenue

August 17, 2022 6921 Views 0 comment Print

Section 263 cannot be invoked to correct each and every type of mistake or error committed by the AO; it is only when an order is erroneous as also prejudicial to Revenue’s interest, that the provision will be attracted.

No addition for mere registration of property in Assessees name without actual transfer of money

July 10, 2022 1851 Views 0 comment Print

Adilakshmi Srungavarapu Vs ITO (ITAT Visakhapatnam) Admitted facts are that the husband of the assessee in order to retain the property got the property registered in the assessee’s name and has repaid the loans borrowed by him by sale of gold jewellery and personal savings of the assessee. We also find merit in the argument […]

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

April 24, 2022 3678 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 3597 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 672 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 3222 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 4140 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 1503 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.

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