“unexplained investment”

Cash Credits & Unexplained ItemsSection 69Section 695,821 judgments

The decision most relied on for unexplained investment is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on unexplained investment

Sumati Dayal v. CIT

214 ITR 801 · 1995 · Supreme Court

1,967

citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

K.P. Varghese v. ITO

131 ITR 597 · 1981 · Supreme Court

989

citing judgments

An addition to income cannot be made merely on the basis of a difference in valuation of assets or a Valuation Officer's report without establishing actual understatement of consideration or the source of unexplained funds through proper enquiry. The Assessing Officer must conduct proper enquiry and satisfy the conditions for making such additions.

Chuharmal v. CIT

172 ITR 250 · 1988 · Supreme Court

340

citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

CIT v. Kamdhenu Steel & Alloys Ltd.

361 ITR 220 · 2014 · High Court

328

citing judgments

When making an addition under section 68, the creditworthiness or financial strength of an investor contributing share capital or share application money can be proved by producing their bank statements showing sufficient balance for the investment. The Supreme Court dismissed the SLP against this decision.

CIT v. Dwarkadhish Investment (P) Ltd.

330 ITR 298 · 2011 · High Court

218

citing judgments

An assessee cannot be asked to explain the source of the source for cash credits, particularly share capital or share application money, once they have discharged the initial onus regarding the identity, genuineness of the transaction, and creditworthiness of the immediate investor.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.

56 Taxmann.com 286 · 2015 · High Court

196

citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

ITO v. Ch. Atchaiah

218 ITR 239 · 1996 · Supreme Court

149

citing judgments

Under the Income-tax Act, 1961, the Assessing Officer must tax any taxable income in the hands of the correct assessee to whom it truly belongs, having no option to assess it in any other person's hands.

CIT v. Stellar Investment Ltd.

192 ITR 287 · 1991 · High Court

146

citing judgments

Once the identity of the shareholders is established, no addition can be made in the hands of the assessee company under Section 68 for share capital or share application money, as it cannot be treated as undisclosed income.

Judgments citing unexplained investment

Lala Sher Singh Memorial Jeevan Vigyan Trust Society, Delhi vs. PCIT (Central)-3, Jhandewalan New Delhi, Delhi

In the result, the assessees‟ appeals are allowed

ITA 10/DEL/2025[2024-25]Status: DisposedITAT Delhi16 Jun 2025AY 2024-25

Bench: Shri C. N. Prasad & Shri M. Balaganeshlala Sher Singh Memorial Vs. Pcit(Central)-3, Jeevan Vigyan Trust Society, Jhandewalan, New Plot No. 18, Sector-22, Phase-1, Delhi Dwarka, Delhi-110075 (Appellant) (Respondent) Pan: Aaaal2241H Jindal Charitable Society, Vs. Pcit(Central)-3, Ps-2, C-3, Block, Phase-Ii, Jhandewalan, New Ashok Vihar, Delhi- 110052 Delhi (Appellant) (Respondent) Pan: Aaatj0588L Florence Nighingale Vs. Pcit(Central)-3, Educational Society, Jhandewalan, New Sector-16B, Phase-I, Haf Delhi Pocket-A, Sector-22, Delhi- 110075 (Appellant) (Respondent) Pan: Aaaaf1097R

For Appellant: Shri Mahesh Kumar, CAFor Respondent: Shri Jintender Singh, CIT DR

Section 119Section 12ASection 132Section 80G

Matharoo in systematic tax evasion i.e. raising funds from public through cash and cheque, siphoning of funds from trusts/ societies for personal use and unexplained investments. The cases belonging to Smt Sudha Gupta and Shri Devendra Gupta group including the assessee were centralized to Central Circle 29 from Circle (Exemptions

Vasantiben Nareshbhai Tandel, Daman vs. ITO, Ward-5, Vapi

In the result, appeal of the assessee is allowed for statistical purposes

ITA 956/SRT/2024[2010-11]Status: DisposedITAT Surat13 Jun 2025AY 2010-11

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.956/Srt/2024 Assessment Year: (2010-11) (Hybrid Hearing) Vasantiben Nareshbhai Tandel, Vs. The Ito, House No.61/1, Kadaiya, Machhiwad, Ward - 5, Nani Daman – 396210, Damand & Vapi Diu (Ut) "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahspt6036E (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Hardik Vora, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/06/2025 Date Of Pronouncement 13/06/2025

Section 144Section 147Section 148Section 250Section 271(1)(c)

well as law on the subject, the learned CIT(A) has erred in confirming the addition of Rs. 1,88,04,680/- on account unexplained investment. of 6. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred ... filed any reply/submission nor any explanation. Therefore, AO issued show cause notice as to why Rs.1,88,04,679/- should not be treated as unexplained investment. Again, there was no compliance. Thereafter, the AO has completed the assessment order u/s 144 of the Act, on the basis of materials available

Ashok Kumar Agrawal, Visakhapatnam vs. Deputy Commissioner of Income Tax, Central Circle-1, Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 136/VIZ/2025[2006-07]Status: DisposedITAT Visakhapatnam13 Jun 2025AY 2006-07

Bench: Shri Veeravalli Durga Rao, Hon’Ble

Section 127Section 143(1)Section 143(2)Section 153ASection 245C(1)Section 245D

sae sei afte, feemaneua te, fexmarmeursy IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM Mt drach gui wa

Deputy Commisioner of Income Tax Circle 3(1)(1) Ahmedabad, Ahmebabad vs. Vijay Manubhai Hirpara, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 668/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad13 Jun 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2015-16

Section 143(3)Section 144Section 14ASection 263Section 56(2)(vii)Section 69

erred in law and on facts in deleting the addition of Rs.70,24,110/- made by AO on account of unexplained investment in immovable property u/s.69 of the IT Act? (d) The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs.15 ... erred in law and on facts in deleting the addition of Rs.37,77,200/- made by AO on account of unexplained investment in agricultural land u/s.69 of the Act. (f) The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs.1,73,172/- made

Shivani Batra, Noida vs. ITO, Ward - 3(4), Nodia

In the result, the Appeal of the Assessee in ITA No

ITA 2546/DEL/2024[2011-12]Status: DisposedITAT Delhi13 Jun 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No. 2620/Del/2023 (A.Y 2011-12) Shivani Batra Vs. Ito A-6, Sector 31, Noida, Ward-3(4) Uttar Pradesh Secdtopr-24, Noida, Pan: Arepb2397L Uttar Pradesh

Section 144Section 147Section 148Section 271(1)(c)Section 69

source of investment made in purchase of immovable property could not be ascertained by the A.O. Therefore, treating Rs. 1,50,00,000/- as unexplained investment u/s 69 of the Income tax Act 1961 (‘Act’ for short) has escaped income for Assessment Year 2011-12, opening proceedings

News Builders and Developers Private Limited, Delhi vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 1769/DEL/2024[2009-2010]Status: DisposedITAT Delhi13 Jun 2025AY 2009-2010

Bench: Shri Mahavir Singh & Shri M. Balaganeshnews Builders & Developers Vs. Income Tax Officer, Pvt Ltd, Ward-18(2), 1St Floor, Property No. 1, Delhi Khasra No. 619/7, Opposite Tivoli Garden, Delhi (Appellant) (Respondent) Pan:Aaccn4173E

For Appellant: Shri Aseem Chawla, Sr. AdvFor Respondent: Date of Hearing

Section 143(1)Section 147Section 148Section 69

Appeal) erred in confirming the addition of Rs. 1,01,00,000/- under section 69 of IT Act, 1961 for unexplained investment. 4. The action of the Ld. CIT (Appeal) for not considering the actual sale deed (purchase deed for the appellant) dated 25-06-2010 is wrong ... aforesaid objections of the assessee and proceeded to bring to tax the alleged cash payment of Rs. 1,01,00,000/- as unexplained investment made by the assessee u/s 69 of the Act, which was upheld by ld NFAC in appeal. 8. On perusal of the actual registered sale deed

Shivani Batra, Delhi vs. ITO Ward 3(4), Noida

In the result, the Appeal of the Assessee in ITA No

ITA 2620/DEL/2023[A.Y. 2016-17]Status: DisposedITAT Delhi13 Jun 2025

Section 144Section 147Section 148Section 271(1)(c)Section 69

Vision Exports, Moradabad vs. Assistant Commissioner of Income Tax, Central Circle, Moradabad

The appeal of the assessee is allowed

ITA 2361/DEL/2023[2017-18]Status: DisposedITAT Delhi13 Jun 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2017-18 Vision Exports, Vs Acit, Faridpur, Sambhal Road, Central Circle, Moradabad – 244 001, Moradabad. Uttar Pradesh. Pan: Aajfv0634Q (Appellant) (Respondent) Assessee By : Shri Chetan Agarwal, Ca; Shri Mohammad Ammar, Ca & Shri Tariq Nafees, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 23.04.2025 Date Of Pronouncement : 13.06.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 23.06.2023 Of The Commissioner Of Income-Tax (Appeals), Lucknow-3 (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Cit(A), Lucknow-3/10314/2018-19 Arising Out Of The Appeal Before It Against The Order Dated 30.12.2018 Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Acit, Central Circle, Moradabad (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Chetan Agarwal, CAFor Respondent: Shri Amit Katoch, Sr. DR

Section 127Section 132Section 142(1)Section 143(2)Section 143(3)

order, we find that none of the alleged disclosures on account of alleged outside book purchases, construction of building at Veepur Industrial Area or unexplained investments not recorded in the books have been corroborated by the loose papers. The submission of assessee about the loose papers have not been rebutted ... Counsel that no material pertaining to the assessee was found during the search on 15th December, 2016 showing the existence of any unexplained investment which is evident from ‘Panchnama.’ Further, no admission was made in the statement recorded u/s 132(4) and the admission made in the statement recorded

Urmila Kishan, Angul vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC)

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 191/CTK/2025[2018-19]Status: DisposedITAT Cuttack12 Jun 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(3)Section 250Section 68

Incorrect Invocation of Section 115BBE Section 115BBE of the Income Tax Act, 1961, deals with the taxation of unexplained income, including cash credits, unexplained investments, and other such unexplained amounts. Section 115BBE is applicable only when additions are made under sections 68 to 69D in cases where the nature

Income Tax Officer, Guntur vs. Annapurna Rajavarapu, Guntur

In the result, appeal filed by the revenue is dismissed

ITA 285/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam12 Jun 2025AY 2022-23

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 143(3)Section 69

failed to substantiate the source of purchase with any documentary evidences. Therefore, Ld. AO added the entire amount of Rs.51,06,33,000/- as unexplained investment as per provisions of section 69 of the Act. Assessee has submitted all the details before Ld. AO by stating that she has purchased ... facts and law. 2. The Ld CIT(A) ought to have uphold the addition of Rs.1,32,34,500/- made by the FAO towards unexplained investment u/s69 of the I.T. Act by considering the factual report submitted by the Assessing Officer that the appellant has purchased 43 plots

Sivaji Raju Bellamkonda, Vijayawada vs. Ward3(3)-ITO, Vijayawada

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 162/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam12 Jun 2025AY 2016-17

Bench: Shri V. Durga Rao, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 143(3)Section 69

Assessee has raised following grounds of appeal: “1. That the learned CIT(A) erred in confirming the addition of Rs.15,00,000 as unexplained investment under Section 69, despite the fact that the bank statements of Smt. Padmavathi Bellamkonda now establish a direct fund trail proving the source of investment

Mrs. Reeta Mahesh Dave, Mumbai vs. Income-Tax Officer, Mumbai

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 5063/MUM/2024[2012-2013]Status: DisposedITAT Mumbai12 Jun 2025AY 2012-2013

Bench: Shri Narender Kumar Choudhryassessment Year: 2012-13 Mrs. Reeta Mahesh Dave Income-Tax Officer Shop No. 82, 4Th Lane, Ward 23(3)(6), Mangaldas Market, Vs. Piramal Chamber, 400002. Mumbai. Pan: Aahpd2775J (Appellant) (Respondent) Present For: Assessee By : Shri Bhavesh Shah, Ld. A.R. Revenue By : Shri Kavan Limbasiya, Ld. D.R. Date Of Hearing : 12.06.2025 Date Of Pronouncement : 12.06.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 30/07/2024, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2012-13. 2. In This Case, The Ao Vide Assessment Order Dated 10.12.2019 U/S. 143(3) R.W.S 147 Has Made The Addition Of Rs. 14,80,000/- On Account Of Unexplained Investment U/S. 69 Of The Act. The Assessee Being Aggrieved Challenged The Said Addition Before The Ld. Commissioner Who By Specifically Holding ‘That During The Appellate Proceeding The Appellant Filed A Confirmation From Riddhi Siddhi Recyclers As Additional Evidence, But Failed To Provide Explanation Against The Contention Of The Ld. Ao That How Any Investor Can Invest In 2 Mrs. Reeta Mahesh Dave Off Market Mode In A Company Who Does Not Have A Sound Financial Standing. The Appellant Also Did Not File The Basic Documents Such As 1. Share Application 2. Number Of Shares Allotted & Photocopy Of The Share Certificate 3. Copy Of Bank Statement With Cheque Number & Bank, On Which The Cheque Was Drawn. In The Absence Of Above Basic Documents, The Genuineness Of So Called Investment Could Not Be Established’ Ultimately Affirmed The Aforesaid Addition.

For Appellant: Shri Bhavesh Shah, Ld. A.RFor Respondent: Shri Kavan Limbasiya, Ld. D.R

Section 143(3)Section 250Section 69

vide assessment order dated 10.12.2019 u/s. 143(3) r.w.s 147 has made the addition of Rs. 14,80,000/- on account of unexplained investment u/s. 69 of the Act. The Assessee being aggrieved challenged the said addition before the Ld. Commissioner who by specifically holding ‘that during the appellate proceeding

Raghunath Maruti Bhosale, Pune vs. ITO Ward 2(1), Pune

In the result, appeals of the assessee for A

ITA 1033/PUN/2025[2010-11]Status: DisposedITAT Pune11 Jun 2025AY 2010-11

Bench: Dr. Manish Boradआयकर अपील सं. / Ita No.1032&1033/Pun/2025 धििाारण वर्ा / Assessment Year: 2005-2006 & 2010-11 Vs Ito, Ward- Shri Raghunath Maruti Bhosale, 2(1), Kolhapur Lalashree, 32B, Laxmi Vasahat, Jawahar Nagar, Kolhapur-416012 Maharashtra Pan-Aazpb3548D Appellant Respondent

For Appellant: NoneFor Respondent: Shri Dayanand

Section 132Section 143(3)Section 250

circumstances of the case the Learned CIT(A) has erred in confirming additions of Rs. 7,50,000/- in the hands of assessee as unexplained investment. 3. On facts and in circumstances of the case the learned CIT(A) has erred in law and on merit in not considering ... made by the Assessing Officer (AO) for unexplained investment. In the first round of proceedings the assessee failed to appear and assessee’s appeal was dismissed by Ld. CIT(A) and then this Tribunal vide order dated 14.06.2019 remanding the issue back to the file

Raghunath Maruti Bhosale, Pune vs. ITO Ward 2(1), Kolhapur

In the result, appeals of the assessee for A

ITA 1032/PUN/2025[2005-06]Status: DisposedITAT Pune11 Jun 2025AY 2005-06

For Appellant: NoneFor Respondent: Shri Dayanand

Section 132Section 143(3)Section 250

Dashrathbhai Madhubhai Jadav, Ahmedabad vs. ITO, Ward-3(3)(1), Ahmedabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 653/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 653/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Dashrathbhai Madhubhai Jadav, The Income Tax Officer, At Post Khoraj Gam, बनाम/ Ward-3(3)(1), V/S. Taluka Sanand, Ahmedabad. Ahmedabad-380001. (Gujarat) "थायी लेखा सं./Pan: Aotpj7754H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Mehul Ranpura, Ar Revenue By : Shri R P Rastogi, Cit-Dr

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 144Section 147Section 148Section 250

erred on facts as also in law in confirming addition made by the AO of Rs. 18,00,000/- being alleged unexplained investment in fixed deposits with Bombay Mercentile Co-op. Bank and Canara Bank on the alleged ground that appellant failed to explain source of investment in fixed deposit

Rajshekar Yadhar, Mandanapalle vs. Income Tax Officer, Ward-1, Madanapalle

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 130/HYD/2025[2016-17]Status: DisposedITAT Hyderabad10 Jun 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri Prasanna Urala, AdvocateFor Respondent: : Ms. Vishnu Priya, SR-DR

Section 143(2)Section 69

treated the peak closing balance in the assessee’s Andhra Bank, savings account, amounting to Rs.11,31,058/- as on 09.10.2015, as unexplained investment u/s. 69 of the Act and added the same to the assessee’s total income. The assessment was completed on 24.12.2018, determining the total income ... made an addition of Rs.11,31,058/- u/s. 69 of the Act, treating the peak balance in the Andhra Bank, savings account as unexplained investment. On appeal, the Ld. First Appellate Authority granted partial relief and sustained the addition to the extent of Rs.8,35,000/-. It is also evident

Shalini Sanjeevi, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 769/CHNY/2025[2016-17]Status: DisposedITAT Chennai10 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita Nos.768 & 769/Chny/2025 िनधा=रण वष= /Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 142(1)Section 144Section 147Section 271(1)(b)Section 273B

order u/s 144 r.w.s. 144B of the Act was passed on 13.12.2023 by making addition of Rs. Rs.1,00,65,900/- on account of unexplained investment. During the assessment proceeding notices u/s 142(1) of the Act were issued three times upon the assessee which were not complied. Therefore

Shalini Sanjeevi, Chennai vs. ACIT, Ncc-7(1), Chennai

In the result, both the appeals filed by the assessee are allowed

ITA 768/CHNY/2025[2016-17]Status: DisposedITAT Chennai10 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita Nos.768 & 769/Chny/2025 िनधा=रण वष= /Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 142(1)Section 144Section 147Section 271(1)(b)Section 273B

Amee Shreyance Shah, Mumbai vs. Income Tax Officer Ward 19(1)(1), Mumbai

In the result, the above appeal of the assessee is

ITA 2450/MUM/2024[2012-13]Status: DisposedITAT Mumbai10 Jun 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Anil Kshatriya, ARFor Respondent: Shri Aditya Rai, (Sr. DR)

Section 10(38)Section 143(3)Section 147Section 148Section 234BSection 271(1)(c)Section 68

kindly be held as genuine. 5) The learned AO erred in law in making the impugned addition u/s, 68 as there were no unexplained investments nor were there any investments not recorded in the books of account of the said amount of Rs.3,72,18,541/- or any other amount ... learned CIT(A) erred in law by upholding the disputed addition under Section 68 of the Income-tax Act, 1961, as there were no unexplained investments nor any investments unrecorded in the books amounting to INR 3,72,18,540/- or any other amount that would justify an addition under

Rupa Vimal Padaliya, Rajkot vs. DCIT, Circle-1(1), Rajkot

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 821/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Jun 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaarrester /Ita No. 821 /Rit/ 2024 (Fara / Assessment Year: (2018-19) (Hybrid Hearing)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 147Section 148Section 69

u/s.147 r.w.s. 144 of the Act dated 27.03.2023 assessing the total income of the appellant at Rs.15,51,000/-on the alleged ground of unexplained investment made for purchase of flat no. A-1101-Cl at Dream City, Rajkot, which includes document value of Rs. 12,50,000/- and alleged