Income Tax Act 2025: Section 105 for Tax Year 2025-26

Unexplained expenses without a valid source or satisfactory explanation are deemed income under Sec 105(1) and not deductible per Sec 105(2) of the Income Tax Act 2025.

Unexplained expenditure

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Unexplained expenditure

[As per the Income Tax Act, 2025 (this Act) w.e.f. 1st April, 2026.]

Section 105(1) of Income Tax Act 2025

1) Where any expenditure has been incurred by the assessee in any tax year, and––

(a) the assessee offers no explanation about the source of such expenditure or part thereof; or
(b) the explanation offered by the assessee is not satisfactory in the opinion of the Assessing Officer,

then, the amount covered by such expenditure or part thereof, shall be deemed to be the income of the assessee for that tax year.

Section 105(2) of Income Tax Act 2025

(2) Irrespective of any other provision of this Act, the amount deemed as income in sub-section (1) shall not be allowed as a deduction under this Act.


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