https://www.taxtmi.com/caselaws?id=782874 ITAT Mumbai allowed the assessee-trust's appeal and deleted the addition made u/s 69C. It held that the addition was based solely on statements of third parties recorded during search, without any seized material, bank trail, or independent corroborative evidence evidencing "cash back" or accommodation entries. The assessee had made donation through banking channels to another registered charitable trust holding valid registrations, duly recorded in its books, thereby discharging its primary onus. The burden then shifted to the Revenue, which failed to prove non-genuineness. ITAT further held that s.69C was inapplicable as the source of expenditure was explained, and that inter-trust donation constituted valid application of income u/s 11. en-us Mon, 01 Dec 2025 00:00:00 +0530 Wed, 03 Dec 2025 12:47:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782874 ITAT Mumbai allowed the assessee-trust's appeal and deleted the addition made u/s 69C. It held that the addition was based solely on statements of third parties recorded during search, without any seized material, bank trail, or independent corroborative evidence evidencing "cash back" or accommodation entries. The assessee had made donation through banking channels to another registered charitable trust holding valid registrations, duly recorded in its books, thereby discharging its primary onus. The burden then shifted to the Revenue, which failed to prove non-genuineness. ITAT further held that s.69C was inapplicable as the source of expenditure was explained, and that inter-trust donation constituted valid application of income u/s 11. Case-Laws Income Tax Mon, 01 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782874