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Corporate TaxArticle·24 April 2026

Section 69A Collapse

By J the App

Executive Summary

Where bank credits are duly recorded in books and supported by documentary evidence establishing identity, source, and genuineness, Section 69A cannot be invoked. 

Further, reassessment proceedings fail where the foundational “reasons to believe” are based on incorrect factual assumptions, thereby vitiating jurisdiction under Sections 147/148.

Issues for Determination

The Tribunal examined whether additions under Section 69A for unexplained bank credits were sustain...

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