SANJITHA REDDY ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(1), BANGALORE

ITA 1173/BANG/2025Status: DisposedITAT Bangalore18 December 2025AY 2016-17Bench: SHRI LAXMI PRASAD SAHU (Accountant Member), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that the assessee had prima facie discharged her onus by filing affidavits from relatives. The AO failed to make proper enquiries regarding the creditworthiness of the donors. Therefore, the Tribunal deemed it appropriate to remit the issue to the AO for a detailed inquiry.

What were the facts?

The assessee, an individual, did not file her return of income. The AO issued a notice u/s 148 after information about property purchase. The AO treated the purchase consideration as unexplained investment u/s 69A after the assessee failed to provide satisfactory explanation, despite submitting affidavits from relatives claiming gifts. The CIT(A) confirmed the addition.

What were the issues?

Whether the addition made u/s 69A for unexplained investment in property purchase was justified, given the assessee's explanation of gifts from relatives and the AO's failure to conduct proper inquiries.

Which sections of the Income-tax Act were involved?

Section 250,Section 69A,Section 148,Section 142(1),Section 133(6),Section 144B,Section 251(1),Section 56(2)(x)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH : BANGALORE

Before: SHRI LAXMI PRASAD SAHU & SHRI SOUNDARARAJAN K.

For Appellant: Shri H. Guruswamy, ITP
For Respondent: Shri Subramanian .S, JCIT-DR

PER SOUNDARARAJAN K., JUDICIAL MEMBER

This is an appeal filed by the assessee challenging the order of the NFAC, Delhi dated 13/05/2025 in respect of the A.Y. 2016-17 and raised the following grounds: Tax effect relating to each Grounds of Appeal Ground of appeal (see note below) The impugned Order u/s. 250 of the Act dated: 13-05-2025 passed by 1. the Ld. CIT(A), NFAC, Delhi is - opposed to law, facts and circumstances of the case. The Ld.CIT(A) NFAC has erred in confirming the Addition made by the AO u/s 69A of the Act amounting to 2. Rs.63,17,522/- Rs.71,23,875/- without appreciating the facts and circumstances of the Case. The Ld. CIT(A)

The order continues below.

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