HARPREET KAUR,OPP. ARYA SMAJ MANDIR, MALOUT, MUKTSAR vs. WARD 2(2), MUKTSAR, WARD, MUKTSAR

ITA 450/ASR/2025Status: DisposedITAT Amritsar06 May 2026AY 2018-1914 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the registered sale deed carries a presumption of correctness in the absence of evidence of payments beyond the recorded consideration. The DVO's report is an opinion-based estimate and cannot substitute the registered deed, especially when the co-owner's assessment accepted the declared investment.

What were the facts?

The assessee, a teacher, jointly purchased a property with her husband for Rs. 40 lakhs as per the registered sale deed. The source of funds was a housing loan and savings. The Assessing Officer reopened the case based on information from the Insight portal, alleging unexplained investment of Rs. 1.50 crores.

What were the issues?

Whether the addition on account of unexplained investment in property is sustainable when the source of funds is explained and supported by a registered sale deed, and the co-owner's assessment was accepted. Whether the reopening of assessment and subsequent additions were legally valid.

Which sections of the Income-tax Act were involved?

Section 69,Section 147,Section 148A,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. UDAYAN DASGUPTA & SH. KRINWANT SAHAY

For Appellant: Adv Sh. Charan Dass, Sr. DR
Hearing: 17.02.2026Pronounced: 06.05.2026

Per: Udayan Dasgupta, J.M.: This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the IT Act, 1961, dated 08.04.2025 which has emanated from the order of AO, assessment unit, passed u/s 147 r.w.s. 144B of the Act, dated 28.03.2023. 2. The grounds of appeal taken in form 36 are as follows:

“1. That the CIT(A) has erred in law and on facts in confirming the addition of Rs. 53,15,100u/s 69, on 2 Assessment Year: 2018-19

account of alleged unexplained investment in the purchase of immovable property (Plot No.85).

2.

That the assessment framed u/s 147 is bad in law, as the notice u/s 148 and the order under section 148A(d) wer

The order continues below.

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