ASHWINI MANOJ NIMBALKAR,MUMBAI vs. ITO WARD 3(1) , NASHIK

ITA 1744/PUN/2026Status: DisposedITAT Pune06 October 2026AY 2015-164 pages
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What did the Tribunal hold?

The Tribunal held that the addition of Rs.17,00,436/- for unexplained investment in immovable property was uncalled for. The Tribunal observed that the assessee's husband had paid Rs.3.50 lakh and Rs.1,45,000/- on 18.12.2014, and Rs.12,26,886/- and Rs.1,000/- on 17.01.2015 from his declared bank accounts (HDFC Bank and Indian Overseas Bank), totaling Rs.17,22,886/-. It was also established that the assessee's husband regularly filed Income Tax Returns, was employed, and had declared a gross income of Rs.14,11,153/- for A.Y. 2015-16. Since these facts remained uncontroverted and the source of the investment was verifiable from the bank accounts, the investment was explained satisfactorily. The finding of the CIT(A) was reversed, and the addition was deleted. The grounds of appeal on merits were allowed.

What were the facts?

The assessee, Ashwini Manoj Nimbalkar, filed an appeal against the order dated 23.03.2026 of the National Faceless Appeal Centre, Delhi, which upheld an assessment order dated 21.02.2024 passed under Section 147 read with Section 144B of the Income Tax Act, 1961. The assessment year in question is 2015-16. The dispute concerns an addition of Rs.17,00,436/- for unexplained investment in an immovable property. The Assessing Officer accepted Rs.70.00 lakh paid from a housing loan taken by the assessee's husband but added the remaining Rs.17,00,436/-. The assessee's appeal before the CIT(A) was unsuccessful.

What were the issues?

1. Whether the addition of Rs.17,00,436/- for unexplained investment in immovable property is sustainable in law, considering the source of funds was explained through the bank accounts of the assessee's husband, turning on Section 69 of the Income Tax Act, 1961. Assessee's contentions: The sum pertains to the purchase of an immovable property. The amount paid through a housing loan was accepted. The remaining sum was paid by the assessee's husband through his bank accounts, which are verifiable. Therefore, the source of investment is explained, and no addition is warranted in the hands of the assessee. Revenue's contentions: The Revenue supported the order of the CIT(A).

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 69

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCHES “SMC”, PUNE

Before: DR.MANISH BORAD

For Appellant: Shri S.N. Puranik
For Respondent: Dr. Amit Munde
Hearing: 25.08.2026Pronounced: 06.10.2026

The captioned appeal at the instance of assessee pertaining to Assessment Year 2015-16 is directed against the order dated 23.03.2026 of National Faceless Appeal Centre, Delhi emanating out of Assessment order dated 21.02.2024 passed u/s.147 r.w.s.144B of the Income Tax Act, 1961 (in short ‘the Act’).

2.

At the time of hearing, ld. Counsel for the assessee requesting for not pressing the legal issues raised by the assessee and the same are therefore dismissed as ‘not pressed’.

3.

As regards the merits, the grounds of appeal revolve around the addition for unexplained investment in the immovable property at Rs.17,00,436/-.

4.

Before me, ld. Counsel for the assessee submitted that the

The order continues below.

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