The Statutory Brief

IT Act 1961 → 2025 / Section 69C

Unexplained income

Section 69C → Section 105

Unexplained expenditure

Section 69C of the old Income-tax Act, 1961 · new section 105 under the Income-tax Act, 2025

New reference Section 105

Income-tax Act, 1961Section 69C

  • Expenditure whose source is unexplained is deemed income
  • Not allowed as a deduction under any head
  • Taxed at 60% under 115BBE

Applies to FY 2025-26 (AY 2026-27) and earlier years.

Income-tax Act, 2025Section 105

  • Section 105(1): same deeming
  • 105(2): not deductible under any provision
  • 30% tax under section 195 (cut from 60% by Finance Act 2026)

Applies from tax year 2026-27 (from 1 April 2026).

What changed

Renumbered, with a real rate change: section 195 rate cut from 60% to 30% by Finance Act 2026; the extra 10% penalty (443) is gone.

Practice notes

  • Bogus purchases are often taxed under this section — keep payment trail and stock records.

These are summaries, not the statutory text. Read the bare Act for both sections on the Income Tax Department's official site, which also has a side-by-side comparison utility.

Frequently asked

What is section 69C in the new Income Tax Act?

Section 105 of the Income-tax Act, 2025.

What changed in section 69C under the new Income Tax Act?

Renumbered, with a real rate change: section 195 rate cut from 60% to 30% by Finance Act 2026; the extra 10% penalty (443) is gone.

Is section 69C still applicable for FY 2025-26?

Yes. Income of FY 2025-26 (AY 2026-27) and earlier years is governed by section 69C of the 1961 Act. Section 105 of the 2025 Act applies from tax year 2026-27.

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