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Facts
The assessee appealed an order related to assessment year 2018-19, concerning an unexplained purchase amount of Rs. 12.19 lakhs in immovable property, as per section 69A of the Income-tax Act. The assessee claimed to have received Rs. 11.50 lakhs via banking channel from his mother, Smt. Renu Gupta.
Held
The Tribunal noted that the source of the purchase amount was supported by a bank transfer from the assessee's mother, and this fact was unrebutted by the Revenue. Therefore, the addition made on this account was not justified.
Key Issues
Whether the addition made under section 69A of the Income-tax Act for unexplained purchase amount is justified when the source is supported by banking channel from mother and unrebutted by the revenue.
Sections Cited
69A, 143(3)
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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Date of hearing 09.02.2026 Date of pronouncement 09.02.2026 ORDER This assessee’s appeal for assessment year 2018-19, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1083176385(1), dated 01.12.2025 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
It emerges during the course of hearing that both the learned authorities have treated the assessee’s purchase amount in immovable property in question to the tune of Rs.12.19 lakhs as unexplained under section 69A of the Act; in assessment order dated 05.07.2021 as upheld in the lower appellate discussion.
That being the case, this tribunal hereby notices from a perusal of the case records that the assessee had in fact received a sum of Rs.11.50 lakhs via banking channel from his mother Smt. Renu Gupta. It is made clear that this clinching fact has gone unrebutted from the Revenue side regarding the source of the assessee’s mother cash in hand which could not have been treated as an unexplained. The impugned addition is directed to be deleted in very terms therefore.