https://www.taxtmi.com/caselaws?id=784789 The dominant issue was whether the assessment order was "erroneous and prejudicial to the interests of the Revenue" under s.263 for not invoking s.69C r/w s.115BBE on disallowed purchases/contract expenses treated as bogus. The ITAT held that s.69C applies only where an expenditure is found and the source of such expenditure is unexplained, whereas disallowance of non-genuine/bogus purchases is a denial of deduction and does not, by itself, convert the amount into unexplained expenditure under s.69C; hence the premise of "lack of inquiry" was legally untenable, and the consequential allegation regarding special-rate taxation under s.115BBE also failed. The s.263 revisionary order was quashed and the appeal was allowed. en-us Wed, 24 Dec 2025 00:00:00 +0530 Mon, 12 Jan 2026 09:31:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784789 The dominant issue was whether the assessment order was "erroneous and prejudicial to the interests of the Revenue" under s.263 for not invoking s.69C r/w s.115BBE on disallowed purchases/contract expenses treated as bogus. The ITAT held that s.69C applies only where an expenditure is found and the source of such expenditure is unexplained, whereas disallowance of non-genuine/bogus purchases is a denial of deduction and does not, by itself, convert the amount into unexplained expenditure under s.69C; hence the premise of "lack of inquiry" was legally untenable, and the consequential allegation regarding special-rate taxation under s.115BBE also failed. The s.263 revisionary order was quashed and the appeal was allowed. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784789