PUNAM SINGH,RANCHI vs. ITO WARD-5(1), PATNA

Per Sonjoy Sarma, Judicial Member: The present appeal filed by the assessee is directed against the order dated 22.12.2025 passed by the Commissioner of Income Tax (Appeal) [hereinafter referred to as the ‘Ld. CIT(A)] u/s 250 of the Income Tax Act, 1961 (the ‘Act’) for the assessment year 2020-21. 2. Brief facts of the case are that, assessee did not file return of income u/s 139(1) of the Act for the assessment year 2020-21. Based on the information received from the insight portal, it was noticed that assessee had purchased an immovable property value at Rs.77,57,400/- which need to initiation of reassessment proceedings u/s 148 of the Act. In

I.T.A. No.47/Pat/2026 Punam Singh; AY: 2020-21 response to the notice issued u/s 148 of the Act, assessee filed return of income declaring total income of Rs.1,85,310/-. During the assessment proceedings, it was noted that detailed investment in property including stamp duty amounting to Rs.78,67,700/-. The assessee explained the source of the investment, stating that redemption from mutual fund of Rs.61,72,366/-, gift from husband of Rs.6,09,750/- and explain Rs.67,82,116/-. The Assessing Officer observed that shortfall of Rs.10,85,584/-. In response, assessee further explained bank balance of Rs.4,52,551/- interest, loan from family friends Rs.7,50,000/-. However, the Assessing Officer accepted only Rs.2,96,301/- out of the bank balance, after considering withdrawals and rejecting the loan claimed due to lack of supporting evidence such as PAN confirmation and credit- worthiness of the lender. The Ld. Assessing Officer after verification accepted the source of Rs.70,78,470/- and treated the balance amount of Rs.7,89,283/- as unexplained investment u/s 69 of the Act, taxable Act u/s 115BBE of the Act. Accordingly, the total income was assessed at Rs.9,74,593/- u/s 147 r.w.s 144B of the Act. 3. Dissatisfied with the above order, assessee preferred an appeal before the Ld. CIT(A), where the appeal of the assessee was dismissed by upholding the action of the Assessing Officer. 4. Still aggrieved by the above order, assessee is in appeal before this Tribunal. At the time of hearing, the Ld. AR categorically stated that the impugned order passed by the Ld. CIT(A) by sustaining the order of the Assessing Officer is bad in law, as assessee has furnished relevant documents to substantiate the sources of the investment and the addition u/s 69 of the Act was without proper appreciation of facts and evidence. Therefore, the impugned order passed by the Ld. CIT(A) needs to be set aside by allowing the appeal of the assessee. During the hearing, the Ld. AR also stated that the assessee is also ready to buy piece and

I.T.A. No.47/Pat/2026 Punam Singh; AY: 2020-21 avoid prolong litigation and offer to surrender Rs.2,00,000/- as additional income and requested that balance addition may be deleted. 5. On the other hand, the Ld. DR supported the order of the authorities below and submitted that the assessee failed to produce adequate supporting documents during the assessment proceedings and the loan claimed was not substantiate with evidence such as identity credit-worthiness and genuineness of the transactions. Therefore, the addition made by the Assessing Officer and sustained by the Ld. CIT(A) was justified. 6. We, after hearing the rival submission and perused the material available on record, it is an admitted position that assessee made an investment in immovable property worth Rs.78,67,700/-. The assessee has explained the substantial portion of the investment which has been accepted by the Assessing Officer. The dispute in the present appeal regarding confirmation of addition of Rs.7,89,283/- treated as unexplained investment. We find that addition was primarily made due to lack of supporting evidence regarding the claim from a family friend and partial bank balance. During the course of hearing before us, the assessee has fairly submitted that in order to avoid future litigation, she is willing to offer Rs.2,00,000/- as additional income. Considering the facts and circumstances and the fact that substantial explanation has already been accepted by the Assessing Officer. We find merit in the submission of the assessee without going into the detailed adjudication on the merit of the addition and considering the offer made by the assessee, we deem it appropriate in the interest of justice and restrict the addition to Rs.2,00,000/-. Accordingly, the addition is restricted to Rs.2,00,000/-,

I.T.A. No.47/Pat/2026 Punam Singh; AY: 2020-21 the balance addition of Rs.5,89,283/- [Rs.7,89,283/- - Rs.2,00,000/-] is directed to be deleted. 7. In the result, the appeal of the assessee is partly allowed.

Kolkata, the 24th April, 2026.

Sd/- Sd/- [Laxmi Prasad Sahu] [Sonjoy Sarma] Accountant Member Judicial Member Dated: 24.04.2026. DP, PS Copy of the order forwarded to: 1. Appellant - 2. Respondent - 3. CIT(A)- 4. CIT- 5. CIT(DR)

//True copy// By order Assistant Registrar, Kolkata Benches