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2019 (3) TMI 1575 - BOMBAY HIGH COURTAddition u/s 69C - unexplained expenditure - expenditure incurred by the assessee to which he offers no explanation about the source of such expenditure - HELD THAT:- In the present case, the revenue had established that the assessee had incurred the expenses outside the books. The assessee failed to offer any explanation. Section 69C therefore, had direct applicability. This, in any case, is an issue based entirely on facts. Two revenue authorities and the Tribunal had concurrently come to factual conclusions which are not perverse. Double taxation - HELD THAT:- Here also we do not find that the assessee has made out any arguable case. As noted the amount was shown to have been assessee’s unexplained expenditure and was, therefore, brought to tax by the A.O. under section 69C. The Tribunal noted that the assessee having taken such an amount on the credit side of the P & L Account, had made corresponding entry on the debit side of the P & L Account claiming the said sum of ₹ 1.75 Crores by way of expenses for the work in progress. Thus, the credit entry was effectively neutralised by corresponding entry on the debit side. This is not, therefore, a case of double taxation.
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