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Facts
The assessee appealed against the CIT(A)/NFAC's order for AY 2019-20, which involved reassessment proceedings. The assessee was absent during the hearing, and the case was decided ex-parte. The lower appellate authority had restricted an addition of unexplained investment from Rs.10,04,400 to Rs.3 lakhs.
Held
The Tribunal noted that the assessee's explanation for the investment as a gift from his son was accepted. For the remaining Rs.3 lakhs, the Tribunal found it plausible that the assessee's accumulated past savings and cash-in-hand, considering his socio-economic status, could explain the amount.
Key Issues
Whether the impugned addition of Rs. 3 lakhs towards unexplained investment could be sustained, considering the assessee's explanation of past savings and socio-economic status.
Sections Cited
147, 148, 143(3), 69
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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Date of hearing 21.01.2026 Date of pronouncement 21.01.2026 ORDER This assessee’s appeal for assessment year 2019-20, 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/250/2025-26/1081990605(1), dated 24.10.2025 involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Case called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte.
Learned departmental representative vehemently argues during the course of hearing that the CIT(A)/NFAC has rightly restricted the Assessing Officer’s action adding unexplained investment amounting to Rs.10,04,400/- under section 69 of the Act to the tune of Rs.3 lakhs only forming subject matter of adjudication before the Tribunal.
I have given my thoughtful consideration to the assessee’s and the Revenue’s respective pleadings all along. There is no dispute that the assessee had explained source of his investment in issue as the sum of Rs.13 lakhs received as a gift from his son which stands accepted in the lower appellate discussion.
Coming to the remaining sum of Rs.3 lakhs herein, this tribunal is of the considered view that possibility of the assesse’s accumulated past savings and cash-in-hand as well as keeping in mind the socio-economic status in such a case could not be altogether denied. The impugned addition stands deleted.