Income Tax Act: Section 69C's Unexplained Expenditure Doesn't Apply to Non-Genuine Expenses, CIT's Claims Invalid.

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....Additions u/s 69C - purview and scope of section 69C is totally different from the disallowance of expenses found to be not genuine - The basic premise with the CIT therefore for finding error in the order of the AO, that the disallowance made by him of contractors’ expense came under the purview of section 69C of the Act is found to be untenable in law. His finding of error, as a consequence whereof, that the same not being subjected to tax at a special rate provided u/s 115BBE of the Act also as a result does not survive. - AT....