VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawConcepts › s.68 and the s.69 family, and the 115BBE rate

s.68 and the s.69 family, and the 115BBE rate

The officer says my cash deposits and loans are unexplained. What section applies and how badly am I taxed?

The officer says my cash deposits and loans are unexplained. What section applies and how badly am I taxed?

Section 68 catches sums credited in your books; ss.69 to 69D catch investments, money, understated investments, expenditure and hundi borrowings that are not in the books at all. Anything brought to tax under these sections is charged under s.115BBE at 60% plus a 25% surcharge and cess — roughly 78% — with no deduction, no allowance and no set-off of loss, and a further 10% penalty under s.271AAC if you did not offer it in your return.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

Section 68 is the only one of the family that needs books. It applies "where any sum is found credited in the books of an assessee maintained for any previous year" and the assessee offers no explanation of the nature and source, or an explanation the Assessing Officer does not find satisfactory. The classic burden is to establish three things about the creditor: identity, creditworthiness and genuineness of the transaction.

The rest of the family deal with things outside the books. Section 69 covers investments not recorded in the books. Section 69A covers money, bullion, jewellery or other valuable articles found in your possession and not recorded. Section 69B covers the case where the books record an investment or article but at less than the amount actually spent — the excess is charged. Section 69C covers unexplained expenditure, and it also denies any deduction for the expenditure so treated. Section 69D covers amounts borrowed or repaid on a hundi otherwise than by account payee cheque.

Section 68 has two special provisos. For a company in which the public are not substantially interested, share application money, share capital and share premium credited in the books are treated as unexplained unless the resident shareholder in whose name the credit stands also explains the nature and source of his own funds and the Assessing Officer accepts it — the "source of source" test, applicable from AY 2013-14. Investment by a SEBI-registered venture capital fund or venture capital company is excepted. The Finance Act 2022 extended a similar source-of-source requirement to loans and borrowings.

Section 115BBE is what makes all of this severe. Income referred to in ss.68, 69, 69A, 69B, 69C and 69D is taxed at 60%, on which a 25% surcharge and cess apply, taking the effective rate to about 78%. The section allows no deduction for any expenditure or allowance and no set-off of any loss against that income. The 60% rate came in with the Taxation Laws (Second Amendment) Act, 2016 and applies from AY 2017-18.

Section 271AAC adds a penalty of 10% of the tax payable under s.115BBE where the income was not included in the return and the tax was not paid; where 271AAC applies, the underreporting penalty under s.270A is not also levied on the same income.

The practical consequence is that the label matters. Business income assessed at ordinary rates against which brought-forward losses can be set off is a completely different outcome from the same figure recharacterised under s.68 or s.69A, even though the quantum is identical.

Why it matters

The difference between an addition sustained as business income and the same addition sustained under s.68 or s.69A is roughly 48 percentage points of tax, plus the loss of every set-off, plus a 10% penalty. That makes the characterisation argument, not the quantum argument, the one worth fighting. It also means unexplained credits in a closely held company's share capital can wipe out the company.

What to do

Where people go wrong

Unsettled, or not pinned down. The department's s.68 page carried only the main limb, not the provisos, so the closely held company proviso and the Finance Act 2022 loans proviso come from professional sources; the assessment year from which the loans proviso operates is not confirmed. The two sources also differ slightly on the effective rate (about 77.25% versus 78%) depending on how cess is applied, and I could not pin the exact assessment year from which the bar on set-off of loss in s.115BBE(2) operates.

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.