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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


Third-Party ERP Entries Alone Cannot Justify Section 69 Addition: ITAT Deletes Jewellery Purchase Addition

May 18, 2026 381 Views 0 comment Print

The Tribunal held that entries found in third-party ERP software during a search cannot alone justify unexplained investment additions under Section 69. Absence of corroborative evidence led to deletion of the entire addition.

Reassessment Quashed for Ignoring Reply Filed Under Section 148A(b): ITAT Slams ‘Borrowed Satisfaction’

May 18, 2026 366 Views 0 comment Print

The Tribunal held that reassessment proceedings were invalid where the Assessing Officer ignored the assessees detailed response and documentary evidence. ITAT ruled that such action violated principles of natural justice and reflected non-application of mind.

Goat Trader Fails to Explain ₹7.10 Crore Bank Deposits: ITAT Upholds Section 69A Addition Despite U/s 44AD Claim

May 18, 2026 426 Views 0 comment Print

The Tribunal held that merely declaring presumptive income under Section 44AD does not exempt taxpayers from explaining massive bank credits. In absence of purchase records, bills, or confirmations, Section 69A addition was sustained.

Cancelled Property Deal Cannot Trigger Section 69 Addition: ITAT Deletes ₹4.96 Lakh Unexplained Investment Addition

May 18, 2026 213 Views 0 comment Print

ITAT Ahmedabad held that no unexplained investment addition could survive where the booked property deal was cancelled and funds were refunded. The ruling emphasized verification of actual payment flow and subsequent cancellation events.

Hyderabad ITAT Upholds Reopening Beyond 3 Years Though Final Addition Was Below ₹50 Lakhs – Jurisdiction Based on Reopening Information

May 18, 2026 354 Views 0 comment Print

The Tribunal held that validity of reopening under Section 148 must be tested on the basis of material available when reassessment proceedings are initiated. Subsequent reduction in additions does not invalidate jurisdiction already assumed.

Section 271AAC Penalty Unsustainable After Assessment Is Quashed: ITAT Delhi

May 16, 2026 549 Views 0 comment Print

ITAT Delhi held that penalty under Section 271AAC cannot survive once the underlying Section 153C assessment is quashed. The Tribunal deleted the penalty after noting that the quantum assessment itself no longer existed.

5-Day Share Trade Cannot Automatically Become ‘Bogus Penny Stock’: ITAT Mumbai

May 16, 2026 2148 Views 0 comment Print

The Tribunal ruled that a genuine share transaction resulting in a short-term loss cannot automatically be treated as a make-believe or accommodation entry transaction. The assessee’s regular trading history supported the genuineness of the transactions.

AO Cannot Apply Post-2018 “Look-Through” Valuation Retrospectively – ITAT Deletes Massive Section 56 Additions

May 16, 2026 255 Views 0 comment Print

ITAT Mumbai deleted additions exceeding ₹10.57 crore made under section 56(2)(vii)(c) after finding that the Assessing Officer wrongly adopted an amended valuation approach retrospectively. The Tribunal upheld the CIT(A)’s deletion in entirety.

No Section 56 Addition as Property Value Difference Was Within 10% Tolerance Band

May 15, 2026 420 Views 0 comment Print

ITAT Mumbai deleted the addition under Section 56(2)(vii)(b) after holding that a 2.3% variation between agreement value and stamp duty value fell within the permissible tolerance band applicable retrospectively.

Customs Valuation Difference Alone Cannot Prove Undisclosed Purchases: ITAT Mumbai

May 14, 2026 360 Views 0 comment Print

Mumbai ITAT observed that assessable value under customs law may differ from invoice value and such variation by itself cannot justify addition under Section 69C without further evidence.

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