This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
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S. 69C: Unexplained expenditure-Alleged bogus purchases-Produced documentary evidence such as purchase invoices, stock records, RTGS payments, GST returns, supplier confirmations, and segment-wise accounts-Matter was remanded back to the AO to obtain the bank account details of MT Co., and verify whether there exists any cash trail; if no such cashback trail is established upon verification, and payments are found to have remained within the banking system, then the addition is to be restricted only to the embedded profit element @ 5 per cent. [S. 145]

Leela Greenship Recycling (P) Ltd. v. DCIT (2025) 237 TTJ 471/ 180 taxmann.com 407 (Ahd)(Trib)

S. 69A: Unexplained money-Credit card expenses incurred in representative capacity-Reimbursed expenses-Addition was deleted-Seizure of gold jewellery-Source explained-Addition was deleted. [S. 132]

Paul Dhinakaran v. DCIT(2025) 237 TTJ 850 (Chennai)(Trib)

S. 69A: Unexplained money-Cash deposit in bank account-Matter remanded to the file of CIT(A)-Reassessment was affirmed.[S. 147, 148]

Akshat Loyalka v. ITO (E) (2025) 237 TTJ 200/ 126 ITR 373/ 175 taxmann.com 42 (Jaipur)(Trib.)

S. 69: Unexplained investments-Non-Resident-Investment in property-Co-owner-Source of investment was explained-Addition was deleted.

Nilesh Purshottam Ghodasara v. DCIT (2025) 237 TTJ 618 (Delhi) (Trib.)

S. 69: Unexplained investments-Capital introduced by partner-The explanation furnished by the assessee cannot be rejected merely on suspicion-Order of CIT(A) deleting the addition was affirmed.

ITO v. Kalidas Jivabhai Patel (2025) 237 TTJ 95 (Ahd)(Trib)

S. 68: Cash credits-Share capital-Addition already made in the hands of investor companies-Amount cannot be taxed again in the hands of the assessee company as the Act does not envisage taxation of the same income twice over on one passage of money.

ACIT v. Double Plus Software (P) LTD. (2025) 237 TTJ 769 (TM) (Delhi) (Trib.)

S. 68: Cash credits-Advance received from customers of the housing project-Offered to tax such advances received in the subsequent years-Addition was not justified-Entitled to claim deduction under s. 80-IA-Addition was rejected. [S. 80IA]

Kumar Urban Development (P) Ltd. v. DCIT (2025) 237 TTJ 881 (Pune) (Trib.)

S. 68: Cash credits-Cash deposits-Demonetization-Survey-Cash sales accepted-Auditors have certified that proper books of account as required by law have been kept by the assessee and books of account give a true and fair view of profit-The rejection of the books of account by the CIT(A) was held to be not justified-Addition was deleted. [S. 69A, 133A, 145(3)]

Peeyush Agarwal v. ITO (2025) 237 TTJ 515 (Jaipur)(Trib)

S. 68: Cash credits-Difference between amount of loan shown in audit report and confirmation-Filed confirmation-two separate account-Deletion of addition was affirmed.

ITO v. Somila Texfab (INDIA) (P) LTD. (2024) 237 TTJ 333 (Jodhpur)(Trib)

S. 68: Cash credits-Share application money-On account of convertible equity warrants from companies which are operated by an entry operator –AO was justified in treating the amount as unexplained income of the assessee. [S. 131(IA) 132(4),133(6)]

ITO v. Evexia Lifecare Ltd. (2025) 237 TTJ (Ahd) 1(Ahd)(Trib)