The Tax Publishers

Income tax--Income from undisclosed sources

Addition Under Section 69 on Account of Notional Interest--Whether Justified

Srivatsan Ranganathan

The learned author discusses about the possibility of addition towards notional interest on monies advanced invoking Section 69B of the Act.

n Section 68 to 69D are anti-evasion provisions. Section 68 is on Cash credits, 69 is on unexplained investments, 69A is on unexplained money, 69B investments not fully disclosed in the books, 69C is on unexplained expenditure. The income arising out of these heads are subject to a flat tax of 60% under Section 115BBE without allowing any expense, deduction or set offs.

n Out of these provisions Section 68, 69/69B are widely used. We limit our discussion here to Section 69/69B on investments alone.

n First and foremost, for an income to be taxed under these two Sections there are a number of conditions which are enshrined in the said Sections per se.

n The two provisions are almost analogous with only marginal changes so what applies to one section in this discussion would apply to the other section as well.

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