Chandra Pal v. ACIT ( 2024) 204 ITD 565 (Delhi) (Trib)

S.69C : Unexplained expenditure- Sale transaction- Purchaser confirmed the transaction – Addition is deleted . [ S. 132(4) ]

AO held that  the  assessee had made cash payments  and source remained unexplained hence made under section 69C of the Act .   During course of assessment proceedings the assessee explained that cash was actually 10lakh which was collected and received by Deepak thrice and the final time through Rahish Pal Singh. The assessee was asked to discharge his onus of explanation, nature and source of transaction. The ITAT held that the assessee had discharged his onus of explaining the nature and source of transaction during search proceedings. The court held that there is no justification on facts and in law for impugned additions which directed the ld. AO to delete. The appeal of assessee is allowed.( AY. 2020 -21 )