SATYAVEER,BHARATPUR vs. BHARATPUR, BHARATPUR
What did the Tribunal hold?
The Tribunal held that the assessee's accumulated savings of Rs. 2,43,140/- were reasonable given his age and earning period. Therefore, the addition sustained by the CIT(A) was ordered to be deleted.
What were the facts?
The assessee purchased an immovable property for Rs. 13,14,000/- with a total investment of Rs. 13,93,140/-. The Assessing Officer made a best judgment assessment and added the entire amount. The CIT(A) sustained an addition of Rs. 2,43,140/- as unexplained investment.
What were the issues?
Whether the CIT(A) erred in confirming the addition of Rs. 2,43,140/- as unexplained investment in immovable property.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, JAIPUR “SMC” BENCH, JAIPUR
Before: SMT. ANNAPURNA GUPTA & SHRI KULDIP SINGH
IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR “SMC” BENCH, JAIPUR (PHYSICAL HEARING) BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI KULDIP SINGH, JUDICIAL MEMBER ITA No: 536/JPR/2026 Assessment Year: 2016-17
Satyaveer ITO, S/o Shri Basudev, Ward-1, Vs Gandhi Nagar Colony, Bharatpur. (Respondent) Near Railway Station, Bharatpur. PAN: CYKPS5027F (Appellant)
Assessee Represented: Sh. Rajendra Agarwal, C.A. Revenue Represented: Mrs. Arti Rawat, JCIT Date of hearing : 11-08-2026 Date of pronouncement : 20-08-2026 ORDER PER : KULDIP SINGH, JUDICIAL MEMBER:-
The Appellant, Satyaveer (hereinafter referred to as the ‘assessee’) by filing the present appeal, sought to set aside the impugned order dated 05.01.2026 passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] qua the assessment order for Assessment year 2016-17 on the grounds inter-alia that:-
I.T.A No. 536/JPR/2026 Page No 2 Satyaveer
“1. The Ld. CIT(A) erred in confirming the addition of Rs. 2,43,140/- alleging unexplained investment u/s 69.”
Briefly stated, facts necessary for consideration and adjudication of the issues at hand are : During the scrutiny assessment u/s 147 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”). The AO noticed that the assessee had purchased an immovable property on 15.12.2015 for a consideration of Rs. 13,14,000/- comprised in Khasra No. 115/347 Rakwa 0.6 Hectar, Anah, Tehsil and District Bharatpur on making payment of stamp duty to the tune of Rs. 79,140/-, total investment of Rs. 13,93,140/-, the AO initiated proceedings u/s 147 of the Act. In response to the notice issued u/s 148 of the Act, the assessee has not filed return of income nor submitted documents before the Assessing Officer, who has proceeded to opt for best judgments assessment and thereby made the entire addition of Rs. 13,93,140/- and framed assessment u/s 143(3) of the Act. 3. The assessee carried the matter before Ld. CIT(A) who has partly allowed the appeal and sustained the unexplained money investment of Rs. 2,43,140/- .
I.T.A No. 536/JPR/2026 Page No 3 Satyaveer
Feeling aggrieved with the impugned order passed by the Ld. CIT(A), assessee has come up before the Tribunal by way of filing the present appeal. 5. We have heard Ld. ARs for the appellant and Ld. DR for the Revenue and perused the record available on file. 6. Undisputedly, the assessee has purchased the land during the year under consideration by investing an amount of Rs. 13,93,140/- out of which he had paid Rs. 9,50,000/- through banking channels by receiving Rs. 5,00,000/- from two creditors and claimed the remaining amount of Rs. 4,50,000/- out of accumulated savings in order to explain the balance amount of Rs. 2,43,140/-. 7. Ld. AR for the assessee contended that the assessee is working in a private sector and was having the accumulated saving of Rs. 2,43,140/-. The assessee is 38 years old as is apparent from the record and if taken to have started earning at the age of 25 years, during 13 years of period it is reasonable for a man ordinary prudence who is interested in purchasing immovable property to have accumulated saving of Rs. 2,43,140/-. So in these circumstances, we are of the considered view that accumulated savings by the assessee are taken as duly proved and as such addition of Rs. 2,43,140/- sustained by the Ld. CIT(A) is ordered to be deleted.
I.T.A No. 536/JPR/2026 Page No 4 Satyaveer
Resultantly, the appeal filed by the assessee is accordingly allowed. Order pronounced in the open court on 20-08-2026
Sd/- Sd/- (ANNAPURNA GUPTA) (KULDIP SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER Jaipur Dated:- 20/08/2026. *Santosh. Copy of the order forwarded to: 1. The Appellant- 2. The Respondent- 3. CIT 4. CIT(A) 5. DR, ITAT, Jaipur. 6. Guard File By order,
Asst. Registrar
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