The Tax Publishers

Benefit of Telescoping While Making Addition Under Section 69C

Dr. CA. Nisha Bhandari

Addition under Section 69C can be made only when an expenditure is not satisfactorily explained by the assessee. Whenever any addition is made by the assessing officer during the assessment proceedings and assessee claims that expenditure is made out of such income, then no further addition can be made by invoking provision of Section 69C. The benefit of telescoping is to be given in such cases. The learned author highlights this issue with help of related case law.

1. Addition when can be made under Section 69C

Where in any financial year an assessee has incurred any expenditure, for which he fails to explain any source or explanation offered by him is not satisfactory the amount covered by such expenditure or part thereof, as the case may be, is deemed to be income of the assessee for such financial year under Section 69C.

The following are the conditions precedent for invoking Section 69C :

(a) In any financial year an assessee has incurred any expenditure.

(b) Assessee offers no explanation about the source of such expenditure or part thereof, or the explanation, if any, offered by him is not, in the opinion of the assessing officer, satisfactory.

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