INCOME TAX ACT, 1961

Section 69C

Income from undisclosed sources - Addition under section 69C - Unexplained expenditure in foreign currency for abroad visit -

Assessee had challenged the finding of CIT(A) confirming the addition of Rs. 75,000 on account of unexplained foreign expenditure under section 69C. Various incriminating material were found during the course of search showing that the assessee had carried out foreign travelling. After considering the submissions of the assessee, AO made addition for unexplained expenditure at Rs. 75,000 under section 69C for the foreign travel to Thailand for two persons. However, the assessee in his submission had admitted these amounts to be added as his undisclosed income. Assessee preferred appeal before CIT(A) but failed to succeed and the addition made by the AO was confirmed as CIT(A) observed that no other details had been filed before AO and during the appellate proceedings which could prove that foreign trips were sponsored by pharmaceutical companies for attending medical conferences. Held: Similar addition were made in the hands of the assessee for unexplained foreign expenditure for assessment years 2007-08 to 2010-11 and that issue came before Tribunal for adjudication in appeal. For assessment year 2011-12 assessee had not requested for any relief in the written submission filed before CIT(A). The relief claimed for other years was only regard to wrong application of package rates for preceding years. Since for assessment year 2011-12 no relief had been requested by the assessee himself as there was no difference in the expenditure incurred at the time of visit and the package rates. Thus, there was no merit in Ground raised by the assessee and the same deserves therefore, to be dismissed.

REFERRED :

FAVOUR : Against the assessee.

A.Y. : 2006-07, 2011-12 & 2012-13

INCOME TAX ACT, 1961

Section 69B

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