DAR E IMAAN WELFARE AND EDUCATIONAL TRUST,VELLORE V. ITO, EXEMPTION WARD, CHENNAI

ITA 2259/CHNY/2025

AI Insights

The case involves DAR E Imaan Welfare and Educational Trust appealing against an order from the Commissioner of Income Tax (Appeals), which confirmed the disallowance of a deduction and treated the expenditure as unexplained under section 69C of the Income Tax Act, 1961. The primary contention was whether the evidence provided by the assessee, which included vouchers for purchases, was sufficient to substantiate the claimed expenditures. The Tribunal, after reviewing the evidence, concluded that the vouchers were not self-made and adequately supported the expenditures, thus reversing the decision of the CIT(A).

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 785376 (ITAT-CHENNAI)
• Duration Of Justice: 2 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 28-10-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: C
• Assessment Year: 2019-2020
• Appeal Filed On: 13-08-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: C.P. SOLOMON
• Keywords: Unexplained expenditure
• Section: 69C

Judgement Text

"आयकर अपीलीय अिधकरण, ‘‘सी’’ Ɋायपीठ, चेɄई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI ŵी ऐम. बालगनेश, लेखा सद˟ एवं ŵी एस.एस. िवʷनेũ रिव, Ɋाियक सद˟ क े समƗ Before Shri M. Balaganesh, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.2259/Chny/2025 िनधाŊरण वषŊ/Assessment Year: 2019-20 DAR E Imaan Welfare and Educational Trust, No. 434/1, G. Kayide Millath Nagar, Kathiyavadi, Melvisharam, Vellore 632 509. [PAN: AACTD2327B] Vs. The Income Tax Officer, Exemption Ward, Chennai. (अपीलाथŎ/Appellant) (ŮȑथŎ/Respondent) अपीलाथŎ की ओर से / Appellant by : None ŮȑथŎ की ओर से/Respondent by : Shri C.P. Solomon, JCIT सुनवाई की तारीख/ Date of hearing : 22.10.2025 घोषणा की तारीख /Date of Pronouncement : 28.10.2025 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 11.07.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2019-20. 2. When the appeal was taken up for hearing, none appeared on behalf of the assessee nor filed any adjournment petition. Hence we Printed from counselvise.com I.T.A. No.2259/Chny/25 2 proceed to hear the ld. DR, pass order on merits taking in consideration the material available on record. 3. The assessee raised 6 grounds of appeal amongst which, the only issue emanates for our consideration as to whether the ld. CIT(A) is justified in confirming the disallowance of claim of deduction and treating the same as unexplained expenditure under section 69C of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances of the case. 4. It is noted that the Assessing Officer added an amount of Rs.2,23,149/- under section 69C of the Act on account of unexplained expenditure in the absence of any evidence to that effect which is clear from paras 1 and 2 of the assessment order. In the first appellate proceedings, the ld. CIT(A) vide para 5.1 of the impugned order discussed the issue and held the evidence adduced by the assessee referring to page 17 of the impugned order, which was held to be in the form of self-made vouchers, not sufficient in support of the contention of the assessee relating to the impugned addition. On perusal of the same, i.e., the sample vouchers, which were reproduced in page 17 of the impugned order, it is noted that the said expenditure incurred for purchase of stationery and books for the purpose of assessee’s business approved and acknowledged by the recipient, which clearly shows that Printed from counselvise.com I.T.A. No.2259/Chny/25 3 the said expenditure from the books. Therefore, we are of the opinion that holding the same as self-made vouchers by the ld. CIT(A) is not tenable, cannot be held to be unexplained expenditure under section 69C of the Act. Thus, the order of the ld. CIT(A) is not justified, the addition confirmed thereon, is deleted. Grounds raised by the assessee are allowed. 5. In the result, the appeal filed by the assessee is allowed. Order pronounced on 28th October, 2025 at Chennai. Sd/- Sd/- (M. BALAGANESH) ACCOUNTANT MEMBER (S.S. VISWANETHRA RAVI) JUDICIAL MEMBER Chennai, Dated, 28.10.2025 Vm/- आदेश की Ůितिलिप अŤेिषत/Copy to: 1. अपीलाथŎ/Appellant, 2.ŮȑथŎ/ Respondent, 3. आयकर आयुƅ/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय Ůितिनिध/DR & 5. गाडŊ फाईल/GF. Printed from counselvise.com "