This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings pronounced in September 2026 in which Section 69C of the Income-tax Act, 1961 — dealing with unexplained expenditure — was among the sections engaged. The cases span benches at Mumbai, Delhi, Ahmedabad, and Bangalore, and arise from a range of contexts including bogus-purchase additions, penalty proceedings, search assessments, and reassessment notices. The compilation is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for primary-source research on Section 69C litigation trends.

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Readers must verify each ruling against the full judgment text, check for any stay, appeal, or reversal, and consult qualified advisers before drawing conclusions for any specific matter.

The statutory framework in one paragraph

Section 69C of the Income-tax Act, 1961 provides that where in any financial year an assessee has incurred any expenditure and the assessee offers no explanation about the source of such expenditure, or the explanation offered is not, in the opinion of the Assessing Officer, satisfactory, the amount of such expenditure — or such part thereof as is so unexplained — may be deemed to be the income of the assessee for that financial year. Unlike certain other deeming provisions, the proviso to Section 69C specifies that such deemed income shall not be allowed as a deduction under any other provision of the Act, making it a particularly consequential addition when sustained.

The 12 rulings

1. Bharti Chirania,Mumbai vs DCIT, Circle - 23(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 9 September 2026
Sections engaged: 10(38), 68, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee against the orders of the learned Commissioner of Income Tax (Appeals) and covered ITA Nos. 4175/MUM/2026 and 4176/MUM/2026 for Assessment Years 2014-15 and 2015-16 respectively. The source preview confirms the proceedings before the Mumbai Bench and the involvement of sections including 69C, but does not disclose the substantive findings or the final direction of the order per the available text.

2. Anil Kumar Singhal,Delhi vs ITO Ward 63(30), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 9 September 2026
Sections engaged: 271(1), 271(1)(c), 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 2551/DEL/2026 arose for Assessment Year 2008-09 from the order of the CIT(A)/NFAC, Delhi dated 09.01.2026. Per the source preview, during the quantum assessment proceedings the Assessing Officer had made an addition of Rs. 16,92,270/- under Section 69C on account of alleged bogus purchases; aggrieved by the assessment order, the assessee preferred an appeal before the CIT(A), who set aside the assessment order and restored the matter — the current appeal before the ITAT relates to penalty proceedings under Section 271(1)(c) arising from that addition.

3. Rinkeshkumar Lalbhai Patel,Ahmedabad vs The ITO, Ward-7(2)(1), Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 8 September 2026
Sections engaged: 115B, 133(6), 144B, 147, 148, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 2451/AHD/2025 for Assessment Year 2017-18 was directed against the order dated 18/11/2025 of the NFAC, Delhi, which had dismissed the appeal against the Assessment Order dated 19/02/2025 passed under Section 147 read with Section 144B. The source preview references credit card transactions aggregating Rs. 64,00,050/- across two banks, which appear to form part of the disputed facts; the substantive findings on Section 69C are not disclosed in the available preview.

4. Assistant Commissioner Of Income-Tax vs Maheshkumar Rajanikant Mandalia

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 8 September 2026
Sections engaged: 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal in IT(SS)A No. 38/AHD/2023 was filed by the Revenue against the order of CIT(A)-11, Ahmedabad dated 10.02.2023, arising from proceedings under Section 153A for Assessment Year 2017-18. Per the source preview, the assessee had filed a return of income for AY 2017-18 on 31.10.2017 declaring total income of Rs. 23,82,200/-, was processed under Section 143(1), and is engaged in the business of manufacturing and retail trading of gold, diamond, platinum and silver articles; a search and seizure operation had been conducted, with the Section 69C addition forming part of the search-assessment dispute before the Tribunal.

5. Dy Commissioner Of Income Tax, Mumbai vs Wheelabrator Alloy Castings Limited

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 September 2026
Sections engaged: 132, 148, 254(1), 40A(3), 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The order was passed under Section 254(1) of the Income Tax Act, with the appeal involving cross-appeals by both the Revenue and the assessee (PAN: AAACW0462F). The source preview contains a tabulated list of project-wise transactions under a development project named "Forests" across multiple dates in 2022-2023, which appear to form part of the factual matrix; the substantive conclusions on Section 69C and the connected sections are not disclosed in the available preview text.

6. Sudhir Ramesh Patel,Mumbai vs ITO Ward 25(1)(4), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 September 2026
Sections engaged: 10(38), 68, 69A, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 7568/MUM/2025 for Assessment Year 2016-17 was filed against the order of NFAC, Delhi dated 29-Sep-2025. Per the source preview, the assessee challenged the CIT(A)'s confirmation of an addition of Rs. 28,53,500 under Section 68 representing proceeds of sale of equity shares claimed as exempt long-term capital gain, and separately challenged the confirmation of an addition of Rs. 85,605 under Section 69C towards commission paid; both grounds were raised before the Mumbai Bench.

7. Korrun India Private Limited,Maddur vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 7 September 2026
Sections engaged: 133(6), 142(1), 143(2), 143(3), 144B, 145(3), 195, 250, 40(a), 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 2910/BANG/2026 (along with SA 143/BANG/2026) for Assessment Year 2022-23 was filed against the impugned order dated 24/07/2025 passed under Section 250 of the Income Tax Act. The appeal involved a wide range of procedural and substantive sections; the source preview confirms the case identity and bench composition but does not disclose the substantive findings on Section 69C or the other sections engaged in the available text.

8. Vaishali Ketan Gandhi,Mumbai, Vile vs Assistant Commissioner Of Income-Tax

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 September 2026
Sections engaged: 115B, 132, 139, 143(3), 144, 147, 250, 271A, 274, 68, 69, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals in ITA Nos. 6192, 6136 & 6176/MUM/2026 covered Assessment Years 2019-20, 2020-21 and 2022-23. Per the source preview, the matter involved penalty proceedings arising from additions made under Sections 68, 69, and 69C across the three assessment years; the CIT(A) had confirmed penalties of Rs. 2,57,780/-, Rs. 46,346/-, and Rs. 4,90,247/- respectively for the relevant years based on those provisions, with the penalty orders all dated 13.09.2024.

9. Sapphire Developers,Mumbai vs ACIT, Central Circle 8(2), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 September 2026
Sections engaged: 132(4), 143(2), 153A, 250, 68, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals in ITA Nos. 4344 to 4348/MUM/2026 spanned Assessment Years 2013-14 to 2017-18 and arose from search-assessment proceedings under Section 153A. Per the source preview, additions were made under Section 68 in respect of unsecured loans from lenders including M/s Antique Exim Pvt. Ltd. and M/s Vallabh Diamond Pvt. Ltd. across multiple years, with associated interest disallowances also forming part of the dispute; Section 69C was among the sections engaged alongside the unsecured loan additions.

10. Rina Radha Madhab Jena,Mumbai vs Assessment Unit Income Tax Department /

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 4 September 2026
Sections engaged: 44A, 69A, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 3587/MUM/2026 for Assessment Year 2023-24 involved additions for unexplained cash deposits and unexplained expenditure. Per the source preview, the Tribunal's order drew a distinction between the present case — where the issue concerned unexplained cash deposits and unexplained expenditure under Sections 69A and 69C respectively, with the source of cash deposits questioned even though turnover was not disputed — and a cited precedent where the issue was bogus purchases within the scope of business operations; cash deposits from own business amounting to Rs. 3,11,000/- were noted as one item in the particulars.

11. Susheel,Hisar, Haryana vs Income Tax Officer, Hisar, Haryana

Bench: Income Tax Appellate Tribunal - Delhi
Date: 3 September 2026
Sections engaged: 115B, 132(4), 142(1), 147, 148, 148A(d), 44A, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 4325/DEL/2026 for Assessment Year 2019-20 was filed against the order of CIT(A)/NFAC, Delhi dated 01.12.2025. Per the source preview, a preliminary procedural issue arose at the time of filing: the Registry noted the appeal was time-barred by 51 days, and the assessee — described as a small contractor not well-versed with income-tax technicalities — filed a condonation application citing bona fide reliance on his tax consultant, who had been handling the assessment proceedings but failed to file the appeal within time due to inadvertent lapse; the substantive Section 69C grounds are not disclosed in the available preview.

12. Sanjaybhai Khubchandbhai vs Income Tax Officer, Ward-1, Patan -

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 3 September 2026
Sections engaged: 115B, 144B, 147, 148, 148A(b), 148A(d), 250, 271A, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in I.T.A. No. 2316/Ahd/2026 for Assessment Year 2020-21 concerned the assessee, an individual and proprietor of M/s. Sanjay Trading Co., who had filed a return of income for AY 2020-21 on 22.10.2020 declaring total income of Rs. 26,39,710/-. Per the source preview, the Assessing Officer treated GST information as falling within the scope of Explanation 1(i) to Section 148 and proceeded on the basis that the assessee had allegedly undertaken bogus purchases amounting to Rs. 32,55,000/- from M/s Adarsh Traders, Bajrang Nagar, Akbarpur Road, Rura, Kanpur, with that information forming the trigger for reassessment proceedings in which Section 69C was engaged.

Patterns across these 12 rulings

Bogus purchases as the primary Section 69C trigger. Across multiple cases in this set — including the Anil Kumar Singhal (Delhi, AY 2008-09) and Sanjaybhai Khubchandbhai (Ahmedabad, AY 2020-21) matters — the Section 69C addition originated from allegations of bogus purchases, confirming that fictitious or unverifiable purchase claims remain the most frequently litigated factual basis for Section 69C additions before the ITAT.
Section 69C frequently travels with Section 68. Several cases in this compilation — including Bharti Chirania, Sudhir Ramesh Patel, Vaishali Ketan Gandhi, and Sapphire Developers — engage both Section 68 (unexplained cash credits) and Section 69C (unexplained expenditure) in the same appeal, indicating that assessments involving disputed credits on the income side commonly also involve disputed expenditure on the expense side, or commission payments linked to disputed transactions.
Search and special-assessment proceedings are a recurring context. Cases such as ACIT vs. Maheshkumar Rajanikant Mandalia (Section 153A, AY 2017-18) and Sapphire Developers (Section 153A, AY 2013-14 to 2017-18) show that Section 69C additions frequently arise in the search-assessment framework, where the Assessing Officer has access to seized material and the burden of explanation on the assessee is heightened.
Reassessment under Sections 147 and 148 as a gateway. In at least three cases — Rinkeshkumar Lalbhai Patel (Section 147/144B), Susheel (Section 147/148/148A(d)), and Sanjaybhai Khubchandbhai (Section 147/148/148A(b)/148A(d)) — the Section 69C addition reached the ITAT through the reassessment route, with GST or third-party information serving as the trigger under the post-Finance Act 2021 reassessment framework.
Penalty proceedings under Section 271(1)(c) as a downstream consequence. The Anil Kumar Singhal matter illustrates a pattern where a Section 69C addition in quantum proceedings generates a downstream penalty appeal — here under Section 271(1)(c) — confirming that researchers tracking Section 69C litigation must also monitor connected penalty appeals, which may be adjudicated separately and on different timelines.

How to use this compilation

This index is a starting point, not a substitute for primary-source research. Each case listed above should be verified against the full text of the order as published on the official ITAT portal or indiankanoon.org before it is cited or relied upon in any professional context. Order text available in the TaxNoticeAI corpus is subject to the limitations of the source preview; substantive holdings, directions, and quantum figures may appear only in portions of the judgment not captured in the preview.

Researchers should additionally check whether any of the listed orders have been challenged in further appeal — before the jurisdictional High Court under Section 260A of the Income-tax Act, or before the Supreme Court — and whether any stay of the ITAT order has been granted by a superior court. Tribunal orders are subject to reversal or modification at appellate stages, and a ruling indexed here as of its pronouncement date may have a different operative status by the time of consultation.

Finally, Section 69C additions frequently interact with CBDT instructions, circulars on bogus-purchase cases (particularly in relation to accommodation-entry operators identified by investigation wings), and state-level enforcement information fed into the faceless assessment system. Parallel CBDT guidance and departmental instructions relevant to the facts of any specific matter should be reviewed alongside the case law for a complete research picture.

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 69C Unexplained Expenditure: 12 ITAT Rulings (Sept 2026)