6 entries · updated 2026-07-07
Additions under sections 68, 69, 69A and 69C (cash credits, unexplained investments and unexplained expenditure) carry consequences well beyond the quantum: section 115BBE's punitive rate, penalty exposure, and in search cases a presumption the Department reads generously. The defensible line in this case law is consistent: the burden shifts only on evidence, and estimates, statements and third-party material have limits the Tribunals enforce.
The rulings here cover the recurring patterns: purchases disallowed only because a supplier stopped filing returns, section 69C additions built on seized documents that never name the assessee or on a bare DVO estimate, old audited loans re-characterised years later under section 68, additions resting on a retracted statement with no corroboration, and survey-surrendered stock pushed into section 69 to reach the penal rate.
For a CA defending these additions, the practitioner takeaways focus on the evidentiary file (confirmations, ledgers, money trails, cross-examination demands) because that file, assembled early, is what decides the appeal.
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Business income. Where the excess stock connects to the regularly recorded trading stock, §69's presumptive provisions do not apply.
No. Where search yielded no incriminating material, an addition based solely on the DVO's estimate of construction cost cannot stand.
No. An admission alone is not conclusive; without corroborative material, the addition of Rs. 3 crore share application money fails.
No. Loans reflected in prior audited records (Rs. 3.56 crore of the Rs. 4.96 crore) cannot be added under §68 in a later year.
No. Documents seized from a third party that do not contain the assessee's name cannot sustain an addition under §69C.
No. Additions for purchases or sub-contract expenses cannot rest solely on the supplier's non-filing or non-response; genuineness must be examined.