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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

Aakash Universal Limited ( Merged Entity Rajkiran Textiles Pvt Ltd), Mumbai vs. Income Tax Officer Ward 13(3)(1), Mumbai

In the result the appeal filed by the assessee stands

ITA 1197/MUM/2025[2010-11]Status: DisposedITAT Mumbai13 May 2025AY 2010-11

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankar

Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 250Section 68

substantial amount of said loan was received in earlier year and as regards balance, sufficient evidence was produced, same could not be added as unexplained investment in relevant assessment year Section 68 of the Income-tax Act, 1961 - Cash credit (Share capital) - Assessment year 2007 08 - Assessee was engaged

Income Tax Officer, Mumbai vs. Bhagwandas Bherumal Adani, Mumbai

In the result, the appeal of the revenue is dismissed, and the cross-

ITA 5026/MUM/2024[2016-17]Status: DisposedITAT Mumbai13 May 2025AY 2016-17

Bench: Shri Sandeep Gosain & Smt. Renu Jauhriआयकर अपील सं./Ita No. 5026/Mum/2024 (निर्धारण वर्ष / Assessment Year :2016-17) Ito Room No. 522A, Kautilya Bhawan, Bkc, Bandra, Maharashtra-400051 V/S. बनाम Bhagwandas Bherumal Adani Flat No. 63, 6Th Floor, Seva View Bldg., Juhu Tara Road, Juhu, Maharashtra- 400054 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Akupa3831H Appellant/अपीलार्थी .. Respondent/प्रतिवादी प्रति आपत्ति सं./ Co No. 273/Mum/2024 (Arising Out Of Ita No. 5026/Mum/2024) (निर्धारण वर्ष / Assessment Year :2016-17) Bhagwandas Bherumal Adani B-302, Sabita Building, 16Th Road, Bandra West, Maharashtra-400050 V/S. बनाम Ito-1.1.1, Mumbai Room No. 522A, Kautilya Bhawan, Bkc, Bandra, Maharashtra-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Akupa3831H Appellant/अपीलार्थी .. Respondent/प्रतिवादी निर्धारिती की ओर से / Assessee By: Shri Subhash Bains राजस्व की ओर से /Revenue By: Shri Leyaqat Ali Aafaqui सुनवाई की तारीख / Date Of Hearing 18.03.2025 घोषणा की तारीख/Date Of Pronouncement 13.05.2025 Page 2

For Appellant: Shri Subhash BainsFor Respondent: Shri Leyaqat Ali Aafaqui
Section 250Section 69

Rs.5,32,83,600/-made by the A.O. for AY 2016-17 on account of loan balance treated as unexplained investment u/s 69 the IT Act." 2. "Whether on the facts and circumstances of the case and in law the Ld. CIT(A) is correct in not appreciating the fact

Madhurika Dilipkumar Shah, Nadiad vs. The ITO, Ward-1, Nadiad

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

ITA 224/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad09 May 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Ankit Parikh, ARFor Respondent: Shri B.P Srivastava, Sr DR
Section 250Section 69Section 69A

cash by the appellant. 4. The Learned CIT (Appeals) has erred in law and facts by making an addition of Rs.76 lacs as Unexplained Investments under section 69 on account of purchase of immovable property which is actually bought from sales proceeds of immovable property and cash deposited

DCIT, Circle-4(1)(1), Ahmedabad, Vejalpur vs. Sunpoint Trading Limited, Memnagar, Ahmedabad

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

ITA 215/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 May 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Sunil Talati, ARFor Respondent: Smt. Trupti Patel, SR.DR
Section 143(3)Section 144BSection 147Section 148Section 148ASection 250Section 69

deleted the addition of Rs.5,00,00,000/- made by the Assessing Officer (“AO”) under section 69 of the Act, treating it as unexplained investment in the hands of the assessee vide order dated 14.03.2024 passed under section 147 read with section 144B of the Act. Facts of the Case ... notice under section 148 was issued on 07.04.2022. The order under section 148A(d) dated 06.04.2022 recorded the satisfaction that the said amount represented unexplained investment under section 69 of the Act, which had escaped assessment for F.Y. 2017-18. 4. During the reassessment proceedings, the assessee submitted that

Sanjay Nayak, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 458/BANG/2025[2018-19]Status: DisposedITAT Bangalore09 May 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

For Appellant: Shri S Annamalai, AdvocateFor Respondent: Shri E Shridhar, CIT (DR)
Section 132Section 143(3)

source of investment in gold, which he failed to do. Hence, the value of gold at Rs. 8,14,412/- was rightly treated as unexplained investment. The ld. DR vehemently supported the orders of the authorities below. 8. We have heard the rival contentions of both the parties and perused

Income Tax Officer, Thane vs. Aura Navkar Developers, Mumbai

In the result, the appeal of the Revenue is allowed

ITA 6681/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 May 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 Ito, Ward-4(1), Thane Aura Navkar Developers Room No.3, A-Wing, Gala No. 20, The Sidhupura 6Th Floor, Ashar It Park, Vs. Ind. Est. Ltd. Gaiwadi, Wagle Industrial Estate, S.V.Road, Goregaon West, Thane(W),Mumbai-400604 Mumbai- 400062 Pan No. Aazfa 9532 A Appellant Respondent

For Appellant: Mr. Subodh RatnaparkhiFor Respondent: Mr. Ram Krishn Kedia, Sr. DR
Section 142(1)Section 144Section 148Section 250(4)Section 69

purchase of development rights, but despite providing numerous opportunities, no compliance was made by the assessee. Therefore, the ld AO made addition for unexplained investment in purchase of the development rights amounting to Rs. 3,65,00,000/- vide impugned assessment order dated 25/03/2022 passed ... reproduced as under: “ADJUDICATION The appellant has challenged the action of the AO in adding Rs. 3,65,00,000/- as unexplained investments u/s 69 of the income tax act for the impugned assessment year. The appellant is a partnership firm engaged in the business of builders and developers

Sahkari Ganna Vikas Samiti Ltd Unn, Shamli vs. AO NFAC Delhi, Delhi

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 4564/DEL/2024[2020-21]Status: DisposedITAT Delhi09 May 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri J. N. Shukla, AdvFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 115BSection 143(3)Section 144BSection 270ASection 270A(9)Section 271ASection 274Section 69Section 69ASection 80P

determining total income at Rs. 5,85,20,439/- after making addition of Rs. 4,21,05,997/- on account of unexplained investment under section 69 read with section 115BBE of the Act; addition of Rs. 10,20,921/- on account of unexplained income under section 69A read with section

Sahkari Ganna Vikas Samiti Ltd Unn, Shamli vs. AO NFAC Delhi, Delhi

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 4546/DEL/2024[2020-21]Status: DisposedITAT Delhi09 May 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri J. N. Shukla, AdvFor Respondent: Shri Sahil Kumar Bansal, Sr. DR
Section 115BSection 143(3)Section 144BSection 270ASection 270A(9)Section 271ASection 274Section 69Section 69ASection 80P

determining total income at Rs. 5,85,20,439/- after making addition of Rs. 4,21,05,997/- on account of unexplained investment under section 69 read with section 115BBE of the Act; addition of Rs. 10,20,921/- on account of unexplained income under section 69A read with section

Sh. Sher Singh Meena, Alwar vs. ITO, Ward-2(3), Alwar

In the result, the appeal of the assessee is allowed and addition is directed to be deleted

ITA 361/JPR/2025[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

Bench: Shri Gagan Goyal & Shri Narinder Kumarsher Singh Meena, Rajgarh Road, Malakhera, Near Petrol Pump, Alwar 301406 Pan No. Aonpm 2161F ...... Appellant Vs.

For Appellant: Mr. P. C. Parwal, C.A., Ld. ARFor Respondent: Mrs. Swapnil Parihar, JCIT, Ld. DR
Section 115BSection 250Section 69Section 69A

below the relevant provisions of the sections 69, 69A and 69B of the Act as under: Section - 69, Income-tax Act, 1961 - FA, 2024 Unexplained investments. 69. Where in the financial year immediately preceding the assessment year the assessee has made investments which are not recorded in the books

Sunrise Realconsultancy Private Limited, Bhiwadi vs. Income Tax Officer, Ward-Bhiwadi, Bhiwadi

ITA 1308/JPR/2024[2013-14]Status: DisposedITAT Jaipur08 May 2025AY 2013-14
For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 142(1)Section 144Section 147Section 148Section 194HSection 271(1)(b)Section 69

addition of Rs.16,56,453/- made by the Learned Assessing Officer u/s 69 of the Income Tax Act, 1961 on account of alleged unexplained investment for purchase of car. 3. In the facts and circumstances of the case, the Learned CIT(A) has erred in confirming the addition of Rs.31 ... Hence the transaction of commission / brokerage remains undisclosed income and purchase of Motor Vehicles made by assessee company remains unexplained investment. The above information is as per NMS data/details under "P-Z category". Therefore, the case of the assessee company for A.Y. 2013-14 was reopened

Sunrise Realconsultancy Private Limited, Alwar vs. Income Tax Officer, Ward-Bhiwadi, Bhiwadi

In the result, the both the appeals of the assessee are partly allowed

ITA 1307/JPR/2024[2013-24]Status: DisposedITAT Jaipur08 May 2025AY 2013-24

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. S. L. Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 142(1)Section 144Section 147Section 148Section 194HSection 271(1)(b)Section 69

addition of Rs. 16,56,453/- made by the Learned Assessing Officer u/s 69 of the Income Tax Act, 1961 on account of alleged unexplained investment for purchase of car. 3. In the facts and circumstances of the case, the Learned CIT(A) has erred in confirming the addition ... relevant to A.Y. 2013-14. Hence the transaction of commission / brokerage remains undisclosed income and purchase of Motor Vehicles made by assessee company remains unexplained investment. The above information is as per NMS data/details under "P-Z category". Therefore, the case of the assessee company

ACIT, Central Circle-2, Jaipur vs. Unimax Buildestate Pvt Ltd, Jaipur

In the result, the appeal of the revenue as well as cross objection of the

ITA 103/JPR/2024[2014-15]Status: DisposedITAT Jaipur08 May 2025AY 2014-15
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Swapnil Parihar, JCIT-DR
Section 143(2)Section 250

addition has been made in the assessment order on the issue of Purchase of property, hence the additions made by the AO towards unexplained investment made in land to the extent of Rs.2,58,00,000/- and on account of unexplained expenses on registration of the land of Rs.14 ... Assessing officer and has been granted by the appropriate authority. Therefore, we find that the AO has taken up the fresh issue of unexplained investment for purchase of immovable property, which has no connection with the issue of Sale of immovable property for which the matter was selected for limited

Niranjanbhai D. Patel, Ahmedabad vs. The Income Tax Officer, Ward-6(1)(1), Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 470/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad08 May 2025AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Jimit Shah, AR
Section 10(1)Section 143(1)Section 143(3)Section 147Section 2(14)(iii)Section 263Section 271(1)(c)Section 271BSection 44ASection 69

could be supported by competent certification. Consequently, an addition of Rs.1,10,75,262/- was made under section 69 of the Act as unexplained investment. Penalty proceedings were also initiated under section 271(1)(c) for furnishing inaccurate particulars of income. ITA No.449,450, 470 and 471/Ahd/2024

Niranjanbhai D. Patel, Ahmedabad vs. The Income Tax Officer, Ward-6(1)(1), Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 450/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad08 May 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Jimit Shah, AR
Section 10(1)Section 143(1)Section 143(3)Section 147Section 2(14)(iii)Section 263Section 271(1)(c)Section 271BSection 44ASection 69

could be supported by competent certification. Consequently, an addition of Rs.1,10,75,262/- was made under section 69 of the Act as unexplained investment. Penalty proceedings were also initiated under section 271(1)(c) for furnishing inaccurate particulars of income. ITA No.449,450, 470 and 471/Ahd/2024

Niranjanbhai D. Patel, Ahmedabad vs. The Income Tax Officer, Ward-6(1)(1), Ahmedabad

In the result, all four appeals filed by the assessee are allowed for statistical purposes

ITA 449/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad08 May 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

For Appellant: Shri Jimit Shah, AR
Section 10(1)Section 143(1)Section 143(3)Section 147Section 2(14)(iii)Section 263Section 271(1)(c)Section 271BSection 44ASection 69

could be supported by competent certification. Consequently, an addition of Rs.1,10,75,262/- was made under section 69 of the Act as unexplained investment. Penalty proceedings were also initiated under section 271(1)(c) for furnishing inaccurate particulars of income. ITA No.449,450, 470 and 471/Ahd/2024

Ms. Lucky Furniture, Kolhapur vs. Assistant Commissioner of Income-Tax, Central Circle, Kolhapur

In the result, the appeal filed by the assessee stands allowed

ITA 1905/PUN/2024[2019-20]Status: DisposedITAT Pune08 May 2025AY 2019-20

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1905/Pun/2024 िनधा"रण वष" / Assessment Year : 2019-20 M/S. Lucky Furniture, Vs. Acit, Central Circle, 215/11, Opp. Konduskar Petrol Kolhapur. Pump, Nh 4, Gokul Shirgaon, Kolhapur- 416234. Pan : Aagfl7482B Appellant Respondent Assessee By : Shri Bhuvanesh Kankani Revenue By Shri Ramnath P. Murkunde : Date Of Hearing : 11.02.2025 Date Of Pronouncement : 08.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.08.2024 Passed By Ld. Cit(A), Pune-11 [‘Ld. Cit(A)’] For The Assessment Year 2019-20. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held That The Excess Stock Of Rs.52,45,600/- Found During Survey, Be Taxed Under The Head "Profit & Gains From Business & Profession'. Accordingly, The Addition So Made By The Ld. Ao By Categorizing Said Excess Stock Of Rs.52,45,600/-

For Appellant: Shri Bhuvanesh Kankani
Section 115BSection 133ASection 68Section 69B

However, Ld. CIT(A) held that the said additional income of Rs.52,45,600/- shall be taxable u/s 69B of the IT Act as unexplained investment instead of u/s 68 of the IT Act. It is this order against which the assesse is in appeal before this Tribunal ... offered for taxation as an additional income. Therefore, the amount representing excess stock 6 is certainly undisclosed business income and cannot be termed as unexplained investment. Therefore, the presumption is to be drawn that the additional income was derived from the business. Thus, it cannot be said that the source

Dy. Commissioner of Income Tax, Chennai vs. Chetan Kothari, Puducherry

Appeal of the revenue is dismissed

ITA 2909/CHNY/2024[2017-18]Status: DisposedITAT Chennai08 May 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Mr.V.Justin,CITFor Respondent: Ms.Hema Muralikrishnan
Section 143(3)Section 69

account and the incomes reported were circumspect and not reliable. 3. The Ld.ClT(A) erred in deleting the addition of Rs.5.46 crores under unexplained investment u/s 69 by not appreciating the fact that the total turnover of Rs.401,90,27,247/- was on account of entries in VAT returns ... bank accounts were not reflected in the cash book. Accordingly, the AO made addition of amount of Rs.5,46,00,000/- as unexplained investment in banks u/s.69 of the Act. 4. Issue No.1: Addition of Rs.8,02,00,613/-: Assessee further challenged order of assessment

M/S. Frugal Developers (P) Ltd., New Delhi vs. DCIT, New Delhi

ITA 640/DEL/2016[2011-12]Status: DisposedITAT Delhi08 May 2025AY 2011-12

Bench: Shri Shamim Yahya & Shri Anubhav Sharmaitas No.638 To 641/Del/2022 Assessment Years: 2007-08 To 2010-11

For Appellant: Shri Rajeshwer Prashad Painuly, AdvFor Respondent: Ms Amisha S. Gupta, CIT-DR
Section 132(4)Section 292CSection 69

been invested by the assessee out of her undisclosed income and same is being added to the income of the assessee as unexplained investment made by him during the year. ” 6.1 The Ld. CIT(A)-31 confirmed the addition of Rs. 75,00,000/- by stating that in Para ... purchase of flat. It is therefore held that the payment of Rs. 75,00,000/- in cash made by the appellant is an unexplained investment u/s 69 of the I.T. Act and accordingly the addition of the said amount is upheld. Accordingly, Ground no. 2 is dismissed

Vinod Laljibhai Vadsola, Timbadi vs. ITO, Ward-1, Morbi

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

ITA 939/RJT/2024[2017-18]Status: DisposedITAT Rajkot07 May 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 939/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2017-18) Vinod Laljibhai Vadsola Income Tax Officer, Ward-1, Vill. Timbadi, Tal: Morbi- Morbi-363 641 Vs. 363 641 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Alnpv 3995 K (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Appellant By : Shri Rajendra Singhal, A.R. राज"व क" ओर से/Respondent By : Shri Abhimanyu Singh Yadav, Sr. D.R. सुनवाई क" तार"ख/ Date Of Hearing : 05/05/2025 घोषणा क" तार"ख/Date Of Pronouncement : 07/05/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Order (Ay) 2017-18, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax(Appeals) / National Faceless Appeal Centre, Delhi (In Short “Cit(A)”, Dated 09.08.2024, Which In Turn Arises Out Assessment Order Passed By The Assessing Officer U/S 147 R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act” Dated 25.05.2023. The Assessee Has Raised The Following Grounds Of Appeal:- 2. “The Grounds Of Appeal Mentioned Hereunder Are Without Prejudice To One Another. 1. The Ld.Cit(Appeals) Has Erred In Law & On The Facts In Holding Assessment Proceedings As Valid Through: A. The Notice U/S 148 Of The Act Has Been Issued By The Ito, Ward-1, Morbi In Violation Of The Provisions Of Sec. 151A Of Act & The Ita No. 939/Rjt/2024 A.Y.17-18 Vinod L. Vadsola

For Appellant: Shri Rajendra Singhal, A.RFor Respondent: Shri Abhimanyu Singh Yadav, Sr. D.R
Section 147Section 148Section 148ASection 149Section 151Section 151ASection 69A

Ld.CIT(A) has erred in law and on the facts in upholding addition of Rs.26,28,000/- u/s 69A of the Act for unexplained investment in LLP. 3. The Ld. CIT(A) has erred in law and on the facts in upholding addition of Rs.9

Haresh Mohanlal Patel, Rajkot vs. ITO, Ward-2(1)(4), Rajkot

In the result, the assessee’s appeal is partly allowed, in about terms

ITA 725/RJT/2024[2017-18]Status: DisposedITAT Rajkot07 May 2025AY 2017-18

Bench: Dr. Arjun Lal Saini, Accountatn Member. & Shri Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, AR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

source of this amount, deposited during period of demonetization, therefore, the assessing officer made addition to the tune of Rs.11,51,000/-, as an unexplained investment in the hands of the assessee, within the meaning of section 69A of the Act. 4. Aggrieved by the order of the Assessing Officer