https://www.taxtmi.com/caselaws?id=465687 Section 69C was invoked to treat consultancy/professional payments as unexplained expenditure on the ground that genuineness was not proved. The Tribunal held that s.69C applies only where the assessee offers no satisfactory explanation about the source of expenditure; where expenditure is recorded in the books, paid through banking channels, and subject to applicable TDS, s.69C cannot be applied merely for alleged non-substantiation of services. Consequently, the disallowance under s.69C was deleted. On the nature of the professional outgo, the Tribunal accepted that the assessee had capitalised the expenditure and claimed only 1/5th, and that supporting bills/payment evidence existed for other payees; thus, the AO and CIT(A) erred, and all impugned additions were directed to be deleted, allowing the appeal. en-us Fri, 24 Jan 2025 00:00:00 +0530 Tue, 06 Jan 2026 10:37:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465687 Section 69C was invoked to treat consultancy/professional payments as unexplained expenditure on the ground that genuineness was not proved. The Tribunal held that s.69C applies only where the assessee offers no satisfactory explanation about the source of expenditure; where expenditure is recorded in the books, paid through banking channels, and subject to applicable TDS, s.69C cannot be applied merely for alleged non-substantiation of services. Consequently, the disallowance under s.69C was deleted. On the nature of the professional outgo, the Tribunal accepted that the assessee had capitalised the expenditure and claimed only 1/5th, and that supporting bills/payment evidence existed for other payees; thus, the AO and CIT(A) erred, and all impugned additions were directed to be deleted, allowing the appeal. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465687