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“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

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle -4(2), Mumbai

ITA 5629/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Feb 2026AY 2017-18

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Ms. Rutuja Pawar, ARFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 69

dated 22.03.2024 u/s 153C of the Act determining the total income at Rs.5,27,360/- after making an addition of Rs.2,00,000/- as unexplained investment u/s 69 of the Act towards on money receipt alleged to have been paid to M/s. RHIL. ITA Nos.5629, 5633 & 5634/Mum/2025 Mr. Dinesh Jawaraji

Isha Metal Stores, Raipur vs. ACIT, Central Circle-2, Raipur

In the result, appeal of the assessee in ITA

ITA 756/RPR/2025[2019-20]Status: DisposedITAT Raipur23 Feb 2026AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.756/Rpr/2025 "नधा"रण वष" /Assessment Year : 2019-20

For Appellant: Shri Sunil Kumar Agrawal, CA &For Respondent: Dr. Priyanka Patel, Sr. DR

persuasive value, however, a closer scrutiny of the same leads us to the conclusion that the said decision was rendered in the context of unexplained investments as per the scheme of Section 69 of the Act. In Paradise Holidays, the issue pertained to the 12 Isha Metal Stores Vs. ACIT

Beena Kandarpkumar Parikh, Ahmedabad vs. The Dy.CIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the asessee is allowed in above terms

ITA 393/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2015-16

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Rohit Aasudani, Sr. DR
Section 250Section 69

allegation by corroborative evidence to establish the cash trail. 3. Further, it is submitted that the entire addition of the alleged "On- money" as unexplained investment u/s 69 of the IT Act, is based on the excel sheet seized during the search operation carried out at the premises

Kamalkumar Ramkumar Agrawal, Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1975/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR
Section 132Section 147Section 148Section 153CSection 69

statements and did not furnish any evidence to rebut the seized material. Accordingly, the Assessing Officer treated the amount of Rs.56,60,500/- as unexplained investment under section 69 of the Act and added the same to the income of the assessee, thereby assessing the total income at Rs.71 ... relying on judicial precedents, the CIT(Appeals) confirmed that the Assessing Officer was justified in treating the differential amount of Rs.56,60,500/- as unexplained investment. The plea that the addition related to an earlier year was rejected by holding that the relevant year for taxation was the year

Bharti Nehru Kariya, Mumbai vs. ITO Ward 19(1)(1), Mumbai

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

ITA 7104/MUM/2025[2020-2021]Status: DisposedITAT Mumbai23 Feb 2026AY 2020-2021

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21

For Respondent: Manisha Ghind (Virtually appeared)
Section 69A

that the Ld. Assessing Officer has erred in treating an amount of Rs. 1,75,00,000/ Rs. 1,75,00,000/- as unexplained investment u/s 69A of the I.T. as unexplained investment u/s 69A of the I.T. Act, 1961, not only without appreciating the facts of the case

Sejal Paresh Chopra, Mumbai Maharahstra vs. Central Circle 4(2) ACIT Assistant Commissioner of Income Tax, Mumbai Maharashtra

In the result, the appeal filed by the assessee is hereby allowed

ITA 7062/MUM/2025[2020-21]Status: DisposedITAT Mumbai23 Feb 2026AY 2020-21

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 142(1)Section 250Section 69

supporting records. Despite the appellant s explanation and the absence of any corroborative evidence, the AO proceeded to treat the alleged cash amount as unexplained investment under Section 69 and made an addition of Rs.600000 in the assessment order dated 15/03/2024. The CIT(A) upheld the addition without proper appreciation ... determining the total income at Rs.11,62,990/- after Ms. Sejal Paresh Chopra making an addition of Rs.6,00,000/- as unexplained investment u/s 69 of the Act towards on money receipt alleged to have been paid to M/s. RHIL. 4. The assessee was in appeal before the first appellate

Sejal Paresh Chopra, Mumbai Maharashtra vs. Central Circle 4(2) ACIT Assistant Commissioner of Income Tax, Mumbai Maharashtra

In the result, the appeal filed by the assessee is hereby allowed

ITA 7061/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 142(1)Section 250Section 69

supporting records. Despite the appellant s explanation and the absence of any corroborative evidence, the AO proceeded to treat the alleged cash amount as unexplained investment under Section 69 and made an addition of Rs.600000 in the assessment order dated 15/03/2024. The CIT(A) upheld the addition without proper appreciation ... determining the total income at Rs.11,62,990/- after Ms. Sejal Paresh Chopra making an addition of Rs.6,00,000/- as unexplained investment u/s 69 of the Act towards on money receipt alleged to have been paid to M/s. RHIL. 4. The assessee was in appeal before the first appellate

Rita Anil Kapoor, Mumbai vs. Income Tax Officer Ward 19(2)(4), Mumbai

In the result, the appeal is allowed

ITA 6640/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Feb 2026AY 2013-14

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarrita Anil Kapoor National Faceless Assessment Rowhouse No. 6, Grand Paradi, Centre, Delhi August Kranti Marg, Kemps Corner, Vs. [Present Jurisdiction Income-Tax Mumbai-400 036 Officer Ward 19(2)(4)-Mumbai] Pan/Gir No. Atvpk 7073 K (Appellant) : (Respondent) Appellant By : Shri M. P. Lohia Respondent By : Shri Annavaram Kosuri Date Of Hearing : 18.02.2026 Date Of Pronouncement : 23.02.2026 O R D E R Per Saktijit Dey: The Present Appeal By The Assessee, Arises Out Of Order Dated 19.08.2025 Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2013-14. 2. The Solitary Issue On Merit Is Concerning The Addition Of An Amount Of Rs.6,60,37,500/- U/S. 69 Of The Act, Representing Alleged Unexplained Investment In Purchase Of Immovable Property.

For Appellant: Shri M. P. LohiaFor Respondent: Shri Annavaram Kosuri
Section 147Section 69

solitary issue on merit is concerning the addition of an amount of Rs.6,60,37,500/- u/s. 69 of the Act, representing alleged unexplained investment in purchase of immovable property. 3. Briefly, the facts are, the assessee is a resident individual. For the assessment year under dispute, the assessee ... being 50% of the aggregate amount of Rs.13,20,75,000/-, at the hands of the assessee by treating it as ‘unexplained investment’ u/s. 69 of the Act. 3 Rita Anil Kapoor vs. NFAC 5. Though the assessee contested the addition before ld. First appellate authority, however, she was unsuccessful

Idrees Mohammed, Kalaburagi vs. Deputy Commissioner of Income Tax, Central Circle Belagavi

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

ITA 147/PAN/2024[2018-2019]Status: DisposedITAT Panaji20 Feb 2026AY 2018-2019

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.147/Pan/2024 (A.Y.2018-19) Idrees Mohammed, Vs Dcit-Central Circle, Shop 4Cc,New Vegetable Saraf Colony, . Market, Main Road, Khanaput, Kalaburagi-585101, Tilakwari, Karnataka. Belagavi--590001, Karnataka. Pan .No. Aajpi7572E (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Ramesh V Mudhol.Ar Revenue By Shri. Naveen Kumar.B.Cit Dr सुनवाई की तारीख/Date Of Hearing 03.02.2026 घोषणा की तारीख/Date Of Pronouncement 20.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Cit(A)-2 Panaji Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Addition Of Unexplained Investment In Stock By The Assessing Officer.

U/sec 250 of the Act. The assessee has raised the grounds of appeal challenging the order of the CIT(A) sustaining the addition of unexplained investment in stock by the Assessing Officer. 2. The brief facts of the case are that, the assessee is a proprietor of M/s Well Worth ... record. The sole crux of the disputed issue envisaged by the Ld.AR that the CIT(A) has erred in sustaining the addition of unexplained investment u/sec69 of the Act made by the Assessing Officer without providing proper opportunity and overlooking the facts and material evidences. The assesse has filed

Navkar Urbanstructure Ltd., Ahmedabad, Gujarat vs. DCIT, Central Cir -2(2), Ahmedabad, Gujarat

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

ITA 117/AHD/2026[2018-19]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2018-19

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2018-19

Section 115BSection 145Section 147Section 148Section 69

erred in confirming the addition of Rs.27.00,69,123/- made by the Assessing Officer treating the purchases from M/s. Blue Sea Commodities as alleged unexplained investment u/s 69 of the IT. Act 1961 and taxing the same applying the provisions of Sec. 115BBE of the Act. . 5. The learned Commissioner

Rushina Vikram Desai, Ahmedabad vs. Ward 3(3)(2), Income Tax Officer, Vejalpur, Ahmedabad

In the result, the appeal filed by the Assessee is treated as allowed for statistical purpose

ITA 2300/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 10(1)Section 143(3)Section 147Section 2(14)Section 250Section 69Section 69B

held now. 4. The Ld. CIT(A) has erred in making addition u/s. 69B of the Act amounting to Rs.3,00,000/- as unexplained investment without giving opportunity of being heard. It is submitted that the order passed is totally incorrect and illegal and the entire addition made on account

Bhansali & Sons- HUF, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

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

ITA 2073/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2012-13

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2012-13

Section 142(1)Section 144Section 147

sham transaction and added to the income. Further, the purchase consideration of Rs.13,09,732/- in respect of these shares was also treated as unexplained investment and added to income. The assessment was completed u/s. 144 r.w.s 147 of the Act on 31.10.2019 at total income of Rs.18

Seven Energies Odisha Limited, Hyderabad vs. ACIT Circle 3(1), Hyd, Hyderabad

ITA 1518/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1518/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Seven Energies Odisha Vs. Acit, Limited, Circle-3(1), Hyderabad. Hyderabad. Pan: Aatcs5759E (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Sashank Dundu, Advocate राज" व "ारा/Revenue By: Ms. Aditi Goyal, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 05/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 07/02/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 18/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee

For Appellant: Shri Sashank DunduFor Respondent: Ms. Aditi Goyal, Sr.AR
Section 143(3)Section 69

case and appeal against the adverse findings. 5. The learned CIT (Appeals)/NFAC has erred in upholding the addition made on account of unexplained investment by allegedly referring to provisions of Section. 69 of the Act without establishing that the investments were not recorded in the books of account ... Officer, without any change in the scope of scrutiny, 3 Seven Energies Odisha Limited vs. ACIT proceeded to make arbitrary additions referable to alleged unexplained investments, which are beyond the scope of limited scrutiny. 7. The learned CIT (Appeals)/NFAC erred in relying upon several factors and arguments, such

Prafulla Kumar Malakar, Income Tax Officer, Ward-12(1), Kolkata vs. Kalawati Investments & Trading P Ltd., Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 134/KOL/2025[2015-16]Status: DisposedITAT Kolkata20 Feb 2026AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 147Section 148Section 250Section 69

read with section 147 of the Act was passed by the Ld. AO thereby making an addition of ₹79,04,700/- on account of unexplained investment u/s 69 of the Act. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who partly allowed ... appeal of the assessee by deleting the addition of ₹79,04,700/- made by the Ld. AO on account of unexplained investment u/s 69 of the Act and held as under: “5.1. Ground No. 2 & 3 pertains to the issue of initiation of 148 proceedings wherein the assessee claimed that

Jitendra Mafatlal Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

ITA 7743/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

Section 115BSection 147Section 153CSection 69

quashed; 5.1 The Ld. CIT(A) erred in confirming the addition of Rs.2,50,000/- u/s.69 of the Income Tax Act, 1961 as unexplained investments on account of alleged cash payment towards the purchase of shop premises over and above the agreement value of shop. The Ld. CIT(A) failed

Jitendra Mafatlal Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

ITA 7742/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Hon'Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

Section 115BSection 147Section 153CSection 69

quashed; 5.1 The Ld. CIT(A) erred in confirming the addition of Rs.2,50,000/- u/s.69 of the Income Tax Act, 1961 as unexplained investments on account of alleged cash payment towards the purchase of shop premises over and above the agreement value of shop. The Ld. CIT(A) failed

Sudhanshu Infrastructures Private Limited, Bhandup(W) vs. Circle 15(3)(2), Aayakar Bhawan, Mumbai

ITA 7654/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: Smt Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Surji Chheda (Virtually present), ARFor Respondent: Assessee by
Section 143(3)Section 48Section 50CSection 50C(1)Section 56(2)(X)Section 56(2)(x)

relied on by the learned counsel for the assessee had dismissed the appeal filed by the Revenue where the CIT(A) had deleted the unexplained investment in house construction on the ground that the difference between the figure shown by the assessee and the figure of the DVO is hardly

Ramani Mathuraprasad Mishra, Mumbai vs. ITO Ward 22(3)(6), Mumbai

ITA 7543/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Naimish JoshiFor Respondent: Date
Section 143(1)(a)Section 144Section 144BSection 147Section 56(2)(vii)

duty value under section 56(2)(vii)(b) of the Act (b) An amount of INR.1,40,00,000/- was added on account of unexplained Investment for the purchase of the said property. The duplicate additions made in the hands of the Assessee as well as his spouse and dismissal

Parekh Ornaments LLP, Mumbai vs. ACIT CC-2(3), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 6186/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailparekh Ornaments Llp 20, Chandra Villa, Nehru Road, Vileparle (East), Mumbai - 400057 ............... Appellant Pan: Aasfp4562A V/S Assistant Commissioner Of Income Tax, Central Circle – 2(3), ……………… Respondent Prathistha Bhavan, Old C.G.O. Annexe, M.K. Road, Mumbai - 400020 Assessee By : Shri Ketan Vajani Revenue By : Shri Pravin Salunkhe, Sr. Dr

For Appellant: Shri Ketan VajaniFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 143(3)Section 250Section 271ASection 69A

some small difference on account of difference at the time of weighing and measurement. However, such difference cannot lead to the stock being unexplained investment. (c) Without prejudice to the above, the appellant submits that in any case the provisions of section 69A of the Act cannot be applied ... absence of any positive finding that the difference represented unexplained investment of the appellant. Such application of section 69A is only on conjectures, surmises and suspicions and therefore the same is not justified. (d) The appellant further submits that the lower authorities have erred in not appreciating that the difference

Sanjay Mittal, Ambikapur vs. ACIT, Central Circle, Bilaspur

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

ITA 53/RPR/2026[2018-19]Status: DisposedITAT Raipur19 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 53/Rpr/2026 (िनधा"रण वष" Assessment Year: 2018-19) Sanjay Mittal, Hind Unitrade Pvt. Vs Assistant Commissioner Of Income Ltd., Old Bus Stand, Near Maya Tax, Central Circle, Bilaspur, Aaykar Lodge, Ambikapur (C.G.) 497001 Bhawan, Bilaspur (C.G.) 495001 Pan: Adtpm5911C (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri R. B. Doshi, Ca राज" की ओर से / Revenue By : Ms. Bharti Singh, Cit-Dr. सुनवाई की तारीख / Date Of Hearing : 19/02/2026 घोषणा की तारीख / Date Of : 19/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against Order Dated 25.11.2025 Of The Commissioner Of Income Tax (Appeals), Raipur-3 [Cit(A)] Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri R. B. Doshi, CAFor Respondent: Ms. Bharti Singh, CIT-DR
Section 132Section 153ASection 250

made by AO on account of difference between cost of construction debited in books and value estimated by Approved Valuer, treating it as unexplained investment in construction, on the basis of Approved Valuer’s report. The addition made by 1 Sanjay Mittal vs. ACIT, Central Circle, Bilaspur AO and confirmed ... construction of said residential bunglow. Thus, there is a difference of Rs.12,10,62,436/- in cost of construction, which is treated as "unexplained investment" met out of undisclosed sources of income which is not recorded in the books of the assessee. During the course of assessment proceedings, the copy