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Issue Based Tax Defence

Specialised Defence for Specific Additions and Disallowances

Some additions need deep, issue-specific defence - cash deposits, unexplained credits under Section 68, bogus purchases, share capital and premium, capital gains, penny stocks, or disallowances. We build technical, evidence-backed submissions supported by case law to defend each specific issue and resist high-pitched additions.

Deep, Technical Defenceevidence and precedent for each specific issue
Sec 68 Cash Deposits Bogus Purchase Penny Stock
ISSUE DEFENDED
0+Specialised Issues
Case-LawBacked Submissions
EvidenceDriven Defence
PANIndia
Most Requested
Sec 68Cash credits
Cash DepositsDemonetisation
BogusPurchases
Share Capital& premium
Penny StockLTCG / STCG
69 / 69AUnexplained
14ADisallowance
40A(3)Cash expenses
Specific Issues, Specific Defences

Each of these additions has its own settled legal position, evidentiary requirements and line of case law. We defend each on its own terms rather than with generic submissions.

Unexplained Money & Credits

The classic additions on identity, genuineness and source.
  • Sec 68 Unexplained Cash Credit
  • 69 Unexplained Investment
  • 69A / 69B Unexplained Money / Assets
  • 69C Unexplained Expenditure
  • 115BBE Tax Rate Defence

Cash Deposit & Demonetisation

Explaining cash deposits and their source.
  • SBN / Demonetisation Deposits
  • Genuineness of Cash Sales
  • Cash-in-Hand Availability
  • Source of Deposits
  • Books & Stock Correlation

Purchases & Expenses

Defending purchases and expense disallowances.
  • Bogus / Hawala Purchases
  • 40A(3) Cash Payments
  • 40(a)(ia) TDS Disallowance
  • Unverifiable Expenses
  • GP / NP Rate Additions

Share Capital & Premium

Identity, creditworthiness and genuineness of investors.
  • Share Capital / Premium Genuineness
  • Identity - Creditworthiness - Genuineness
  • Sec 56(2)(viib) Valuation
  • Accommodation Entry Allegations
  • Investor Documentation

Capital Gains & Securities

Penny stocks, exemptions and stamp-value additions.
  • Penny Stock LTCG / STCG
  • 10(38) Exemption Defence
  • 50C / 43CA Stamp Value
  • Capital Gains Computation
  • Exemptions u/s 54 / 54F

Other Disallowances

The recurring technical disallowances.
  • 14A / Rule 8D Disallowance
  • Business vs Capital Expenditure
  • Depreciation Disputes
  • Interest Disallowance
  • Deemed Dividend 2(22)(e)

Have a specific addition to fight? tell us the issue

How We Build the Defence
1
Analyse the IssueWe study the exact addition, the section invoked and the department's reasoning.
2
Gather EvidenceWe assemble the documents, confirmations and records that establish genuineness and source.
3
Build Technical DefenceWe prepare a detailed, issue-specific submission on facts and law.
4
Cite PrecedentsWe support the defence with directly applicable High Court, ITAT and Supreme Court decisions.
5
File & RepresentWe file and argue the matter through assessment and, if needed, appeal.

Why Choose Us

Deep Technical ExpertiseCA and advocate strength on exactly these contested additions.
Evidence-DrivenWe win these issues on documentation - and we know precisely what is needed.
Case-Law BackedSubmissions anchored in the latest and most relevant precedents.
Issue-Specific StrategyNo generic replies - a tailored defence for each addition.
Resists High-Pitched AdditionsWe push back hard on excessive and unsupported additions.
Confidential & TransparentDiscreet handling with clear, upfront professional fees.

Documents Usually Required

The exact set depends on the issue - a typical list includes:

  • Assessment order / notice raising the issue
  • Books of account & ledgers
  • Bank statements
  • Purchase & sale invoices
  • Confirmations & PANs of parties
  • Demat & contract notes (securities)
  • Valuation reports, where relevant
Discuss Your Issue
Frequently Asked Questions

Section 68 lets the Assessing Officer treat any unexplained credit in your books - a loan, share capital or deposit - as your income unless you satisfactorily explain its nature and source. The defence turns on proving the identity, creditworthiness and genuineness of the transaction, which we document thoroughly.

By establishing the source of the cash - sales, withdrawals, opening balance or other genuine receipts - and correlating it with your books, stock and past patterns. Demonetisation-period deposits in particular need careful reconciliation, which we prepare in detail.

Where the department alleges purchases are non-genuine or from hawala parties, it may disallow them fully or add a percentage as profit. We defend by proving the movement of goods, payments through banking channels and the correlation of purchases with sales.

Additions treated as unexplained income under Sections 68 to 69C are taxed at a flat 60% (plus surcharge and cess) under Section 115BBE, with no deductions. Because the rate is punitive, we fight both the addition itself and its characterisation under these sections.

Yes. These issues are heavily litigated, and outcomes often turn on directly applicable precedents. We build every defence on the most relevant and recent decisions.

We charge transparent, agreed professional fees based on the issue and the work involved, discussed upfront.

Book a Free Consultation

Facing a specific addition or disallowance? Tell us the issue - we will explain the legal position, the evidence needed and how we would defend it, with no obligation.

Sec 68 / 69 unexplained credits & money
Cash deposits & demonetisation
Bogus purchases & disallowances
Share capital, premium & penny stock LTCG

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Fighting a specific addition? Let’s build a technical, evidence-backed defence.

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