This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings pronounced between 1 July 2026 and 8 July 2026, each engaging Section 69 of the Income Tax Act, 1961 — the provision dealing with unexplained investments. The rulings span seven ITAT benches (Kolkata, Hyderabad, Delhi, Chandigarh, Ahmedabad, Jaipur, and Raipur) and arise from a variety of assessment contexts including cash-deposit additions, search-and-seizure proceedings, reassessment, and faceless appeal orders. This page is intended for in-house tax teams, Big-4 associates, and law-firm researchers who need a structured, citable starting point for further primary-source research.

Research index only — not legal or tax advice. This page summarises publicly available tribunal orders for research purposes. Readers must verify all details against the full judgment text, check for any subsequent stay, reversal, or appeal, and consult qualified counsel before acting on any information here.

The statutory framework in one paragraph

Section 69 of the Income Tax Act, 1961 provides that where, in the financial year immediately preceding the assessment year, an assessee is found to have made investments that are not recorded in the books of account (if any books are maintained), and the assessee offers no explanation about the nature and source of such investments, or the explanation offered is, in the opinion of the Assessing Officer, not satisfactory, the value of such investments may be deemed to be the income of the assessee for that financial year. The section thus places the initial onus on the assessee to explain the source of investments found to have been made during the relevant period; where that onus is not discharged to the satisfaction of the Assessing Officer, the investment amount is treated as unexplained and brought to tax accordingly. Section 69 commonly appears alongside related provisions such as Section 69A (unexplained money, bullion, jewellery, etc.) and Section 68 (unexplained cash credits), and the three provisions often feature together in assessments arising from cash-deposit scrutiny, search-and-seizure operations, and reassessment proceedings.

The 12 rulings

1. DCIT,Circle-49(1), Kolkata, Kolkata vs Sumit Dutta, Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 8 July 2026
Sections engaged: 69, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the revenue (DCIT, Circle-49(1), Kolkata) against the order of the National Faceless Appeal Centre, Delhi, passed under Section 250 of the Act for Assessment Year 2017-18, arising out of ITA No. 846/KOL/2025. The source preview records that the assessee, a senior citizen engaged in the business of gas distribution agency M/s Freedom Services, had filed a return of income for A.Y. 2017-18 declaring total income of Rs. 19,44,20/-, while the Assessing Officer found cash deposits amounting to Rs. 1,97,40,500/- in the bank account of M/s Freedom Services with Bank of Baroda, leading to the additions in dispute.

2. Manikanta Prudhvi Prabhakar vs ITO, Ward-8(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 8 July 2026
Sections engaged: 147, 148, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1800/Hyd/2025) was filed by the assessee against the order of the CIT(A), National Faceless Appeal Centre, dated 17.07.2025, for Assessment Year 2020-21. At the outset, the Tribunal noted a delay of 30 days in filing the appeal; the assessee filed a petition for condonation of delay supported by an affidavit explaining the reasons for the delay, which the Tribunal considered at the preliminary stage before proceeding to the merits of the appeal.

3. Clarion Agro Products Private vs ACIT., Central Circle-3(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 8 July 2026
Sections engaged: 115J, 132, 143(2), 143(3), 153A, 153D, 292B, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1075/Hyd/2025) was filed by Clarion Agro Products Private Limited against the order of the CIT(A)-11, Hyderabad, dated 03.01.2025, for Assessment Year 2019-20. At the threshold, the Tribunal noted a delay of 24 days in filing the appeal before the Tribunal, and the assessee supported the condonation petition with an affidavit explaining the reasons that prevented timely filing; the matter engaged a broad range of search-assessment and related provisions as reflected in the sections cited.

4. Virender Kumar,Bahadurgarh vs Income Tax Officer, Panchkula

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 7 July 2026
Sections engaged: 14, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 64/CHD/2026) was filed by the assessee against the order of the CIT(A), NFAC, dated 14.11.2025, for Assessment Year 2023-24. The source preview records that one of the grounds raised by the assessee challenged the CIT(A)'s decision to uphold an addition of Rs. 19,03,000/- as unexplained investments, with the assessee contending that the Assessing Officer had made the addition on the basis of alleged incriminating material found and seized during a search and seizure action.

5. Tejalben Virambhai Desai,Gandhinagar vs Income Tax Officer, Ward -1

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 7 July 2026
Sections engaged: 115B, 144B, 147, 148, 148A, 148A(b), 148A(d), 151, 271A, 69, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1229/Ahd/2026) was filed by the assessee for Assessment Year 2018-19 against the order of the CIT(A). The source preview shows that a key ground raised by the assessee was that the CIT(A) had a statutory obligation under the Act to decide all grounds of appeal, including additional grounds duly filed and admitted, and that complete non-adjudication of the Additional Ground of Appeal — which raised the validity of reopening — constituted a jurisdictional error and a violation of the principles of natural justice rendering the impugned order unsustainable in law.

6. Infinity Enterprise,Ahmedabad vs Income Tax Officer, Ward-2(1)(2)

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 7 July 2026
Sections engaged: 147, 194C, 250, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 2348/AHD/2025) was filed by Infinity Enterprise, a partnership firm engaged in business activities, against the CIT(A)'s order for Assessment Year 2013-14. The source preview records that one of the assessee's grounds challenged the CIT(A)'s failure to appreciate that granting an opportunity of video conferencing is mandatory in faceless appeal proceedings, and the assessee prayed for deletion of the addition/disallowance of Rs. 7,78,120/- on grounds of natural justice.

7. DCIT ,Central Circle-32, New Delhi, New vs Nirmal Kumar Sarda, Rajasthan

Bench: Income Tax Appellate Tribunal - Delhi
Date: 6 July 2026
Sections engaged: 153A, 250, 68, 69, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter comprised revenue appeals (ITA Nos. 8348 & 8349/Del/2025) and cross-objections by the assessee (CO Nos. 58 & 59/Del/2026) arising out of those appeals, all concerning Assessment Years 2012-13 and 2013-14. The appeals and cross-objections were preferred against the order of the CIT(A)-30, New Delhi, dated 30.08.2025, passed under Section 250 of the Act, with the matter engaging search-assessment and unexplained-income provisions.

8. Prahalad Singh,Kundan Nagar Ajmer vs Assessment Unit Income Tax Department

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 6 July 2026
Sections engaged: 147, 271(1)(c), 44A, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 475/JPR/2025) was filed by the assessee for Assessment Year 2015-16. The source preview records that on the date of hearing, there was no appearance by the assessee or his counsel on repeated calls, whether physically or in virtual mode; the Tribunal noted that the appeal had previously been fixed for hearing on six separate occasions and the assessee had been intimated by registered post and email, yet no representation or response was received on any occasion.

9. Ajaib Singh,Sangrur vs Income Tax Officer, Sangrur

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 1 July 2026
Sections engaged: 147, 148A, 271(1)(c), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 990/Chd/2025) was filed by the assessee against the order dated 06.06.2025 of the CIT(A), National Faceless Appeal Centre, Delhi, for Assessment Year 2015-16, whereby the appeal of the assessee was dismissed. The appeal was heard through physical mode, and no appearance was entered on behalf of the assessee on the date of hearing, with the revenue represented by the Senior DR.

10. Smt. Usha Verma, Surguja,Surguja vs ITO-1, Ambikapur, Ambikapur

Bench: Income Tax Appellate Tribunal - Raipur
Date: 1 July 2026
Sections engaged: 68, 69, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 378/RPR/2026) was filed by the assessee against the order of the CIT(Appeals)/NFAC, Delhi, dated 19.03.2026, for Assessment Year 2015-16. The assessee's counsel submitted before the Tribunal that the assessment order concerned additions on account of cash deposits treated as undisclosed income, but that the CIT(Appeals)/NFAC, while invoking Section 68 of the Act, failed to demonstrate how that provision pertained to the facts of the assessee's case; the assessee further contended that the entire trail of investigation related to ascertaining the source and nature of the cash deposits.

11. Kapish Agarwal,Hyderabad vs ITO, Ward-11(1), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 1 July 2026
Sections engaged: 143(2), 143(3), 144B, 56(2)(x), 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 2407/Hyd/2025) was filed by Shri Kapish Agarwal against the order of the CIT(A), National Faceless Appeal Centre, Delhi, for Assessment Year 2022-23. The appeal was filed by the assessee feeling aggrieved by the NFAC's order; the source preview confirms the matter was heard on 17.06.2026 and pronounced on 01.07.2026, with the assessee represented by a Chartered Accountant and the revenue by a Senior AR.

12. Jitender Parmar,Delhi vs DCIT, Central Circle-31, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 1 July 2026
Sections engaged: 115B, 132, 144, 153C, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 7140/Del/2025) was filed by the assessee against the order of the CIT(A)-30, New Delhi, dated 24.10.2025, for Assessment Year 2020-21, arising from an assessment order dated 19.03.2024 passed under Section 144 read with Section 153C of the Act. The source preview records certain payment transactions dated 18.10.2019 involving amounts of Rs. 13,00,000/-, Rs. 14,00,000/-, and Rs. 13,00,000/- to named parties, which appear to be part of the factual matrix under consideration in the appeal.

Patterns across these 12 rulings

Section 69 as a composite provision in multi-section disputes. In every ruling in this compilation, Section 69 appears alongside at least one other provision — commonly Section 69A, Section 68, or search-and-seizure provisions such as Section 153A or Section 153C. This reflects the practical reality that unexplained-investment additions rarely arise in isolation; they typically accompany cash-deposit, unexplained-money, or search-assessment frameworks.
Cash deposits as the recurring factual trigger. Multiple cases in this set (including Cases 1 and 10) involve cash deposits identified by the Assessing Officer as the proximate basis for additions. The source previews for those cases explicitly reference cash deposits and the question of whether their source and nature were satisfactorily explained.
Delay-condonation as a threshold procedural issue. Cases 2 and 3 both record delay in filing the appeal before the Tribunal at the outset, with the assessee required to file petitions supported by affidavits. This pattern suggests that delay-condonation is a recurring gateway issue in this batch of ITAT proceedings before the substantive merits are reached.
Non-appearance by assessees at hearing. Cases 8 and 9 both record that the assessee or counsel did not appear on the date of hearing — in Case 8, after six prior fixings with intimation by registered post and email. This is a distinct procedural pattern worth noting for researchers studying ex-parte ITAT proceedings in Section 69 matters.
Challenges to faceless appeal proceedings on natural justice grounds. Cases 5 and 6 both record grounds of appeal that directly impugn the conduct of faceless appeal proceedings — Case 5 on the ground of non-adjudication of additional grounds, and Case 6 on the ground that video-conferencing opportunity was not granted. This pattern reflects the ongoing litigation around procedural fairness in the faceless appellate regime where Section 69 additions are also under challenge.

How to use this compilation

This index is designed as a research starting point, not a substitute for reading the full judgment. Each entry above is drawn from the text preview and identity fields captured in the TaxNoticeAI corpus. The source previews are necessarily truncated and may not capture the Tribunal's final reasoning, the ultimate disposal of the appeal, or any directions issued on remand. Before citing any of these rulings in a submission, memo, or opinion, researchers should retrieve the complete order text from the official ITAT portal, indiankanoon.org, or the relevant court's published records, and verify that the order text matches the citation data above.

Researchers should also check whether any of these orders have been subsequently challenged before the High Court or Supreme Court, or whether a stay of the ITAT order has been granted. ITAT orders, while final on facts in most cases, can be appealed on substantial questions of law under Section 260A of the Income Tax Act, and a High Court may have admitted such an appeal or granted interim relief. The absence of a reported High Court proceeding at the time of publication of this compilation does not mean no such proceeding exists.

Finally, for matters engaging search-and-seizure or reassessment provisions alongside Section 69, researchers should cross-reference applicable CBDT circulars, instructions, and the Finance Act amendments relevant to the assessment year in question, as the statutory framework for reassessment and search assessments has undergone significant changes in recent years. Assessment-year-specific procedural rules may materially affect the validity of the underlying proceedings and therefore the precedential weight of any ruling in this set.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 69 Unexplained Investments: 12 ITAT Rulings (2026)