RAJNI MARWAHA,JALANDHAR vs. DCIT, JALANDHAR

ITA 341/ASR/2025Status: DisposedITAT Amritsar25 June 2026AY 2021-229 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the DVO report, being an expression of opinion, cannot be the sole basis for making additions without corroborative evidence. It emphasized the need for tangible material and regular books of account to justify such additions.

What were the facts?

The assessee declared income from undisclosed sources, including investment in residential property. The Assessing Officer (AO) made additions based on a valuation report (DVO report) and other materials, treating a portion of the investment as unexplained. The assessee contested these additions, arguing lack of material on record to support the DVO's findings.

What were the issues?

Whether additions made solely on the basis of a DVO report, without corroborative evidence, are sustainable. The validity of unexplained investment additions made by the AO.

Which sections of the Income-tax Act were involved?

Section 68,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPTLI-ATE ARI}UNAI AMRITS^R BENCII, AMRITSAR B'FORE SIi. MANOJ KUILAR ACC,ARWA]-' AC@UNTANI Mf,MBXR

v. DCIT,ceiftlC t *1. 8sp94!rlr! t;;r-!'!!!!"q!a 98!EB re old' o' o r. Ll( '€ e..'s -0i6l^ 'h. IIA. 06.01 202r, shich ha5 cnmsied 60m tn $det ol tP ,cJT c*ol raraidh#. pased di I ar(r) or'he ^ 't Thdt the a.a.r pdse.! bt thz Hah btecITlA) dnted 06 03.2025 is dsakn th. k\t md fa^ ofthe .6e 2. rhat hd,i4 ftRt.l to the lz.6 atu1 cncuhtmes of.\e ^e Hon bt. clr t 4) h6 en.'t i' tN o"d bn lrt ir rcnnmhc the i" lr.ni,s th. hP ..ioh aJ Ltt. ^o

.',1-';*::#11' II )131r) af the k.ane ld aet a''t withfu e;hptvns fith the nandaba canli tions t1/s t 4 3/ ) 5 JA/ l

t rhat haihs rcEad b nP fads and en&ntua oflhe eare' Hon'bte cIr(A) has qre.! in tN and anfe^ in eanlrnks the dd ol Ld Ao h lioflhE the hpLgnetl 6esntn o'tel ri&ad nnpttins vih tlz hahdatarJ conditia$ * ^ oPpror''| lion rc|1 , c.drat Rdnee rdtmdhat 64at pa*ine a$8snctr adq as the oP,tovt s.mzd s n|h'r 1. l\al hdinE EEara b &e l.ds a encunna'ct 'J he c6e Hanbb cu lt) h6 *ea k tN a'd an ldds k ahJnnhE he odbn afld Ao k mtinE an additiotoft ) 46 e3'6un' neonrc the sotu as otteced 'm\Ptained in 6eB) on restc.dbt prcpe.,

The order continues below.

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