Capitation Fees for Children's Admission Challenged; Commissioner's Justification u/s 69C Deemed Incorrect.

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....Additions made u/s 68 - capitation fee paid for admission of assessee’s children - Though, Commissioner (Appeals) has made an attempt to cover up the legal lacuna by stating that the AO has treated the payment of fee in cash as unexplained expenditure under section 69C, however, such observation of learned Commissioner (Appeals) is factually incorrect, hence, cannot be accepted. - AT....