“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

Mr. Madeneralu Annegowda Subbegowda, Chikmagalur vs. Income Tax Officer, Ward-2, Chickmagalur

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

ITA 2352/BANG/2024[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri N Ramaraju, C.AFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 115BSection 142(1)Section 250Section 69

absence of evidence proving the genuineness of the claimed agricultural income, the AO concluded that the entire deposit of Rs. 15,28,500 was unexplained investment. Accordingly, it was brought to tax under section 69 of the Act as income from other sources and made taxable under section 115BBE

Sri. Maddur Ananthaswamy Srinath, Chitradurga vs. Income Tax Officer, Ward-1, Chitradurga

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

ITA 1579/BANG/2024[2021-22]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-22

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri N Ramaraju, C.AFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 115BSection 142(1)Section 250Section 69

Mr. Anil Bherumal Kalal, Mumbai vs. ITO -19(2)(1), Mumbai

In the result, substantial ground of appeal raised by assessee is allowed

ITA 1189/MUM/2025[2006-07]Status: DisposedITAT Mumbai21 Apr 2025AY 2006-07

Bench: Shri Pawan Singh(Physical Hearing) Mr. Anil Bherumal Kalal Ito – 19(2)(1), Mumbai A-602, Pooja Enclave, S T Braz Road, Kautilya Bhavan, Bkc, Vs. Behind Nanavati Hospital, Vile Parle Bandra (East), Mumbai – West, Mumbai-400056. 400051. Pan: Aabpk 3216 B (Appellant) (Respondent) Assessee By : Shri Subhash Chhajed, Ar Revenue By : Ms. Pradnya Gholap, Sr. Dr Date Of Hearing : 16.04.2025 Date Of Pronouncement : 16.04.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of Ld. Cit(A) Dated 30.12.2024 For A.Y. 2006-07. The Assessee Has Raised The Following Grounds Of Appeal: “Validity Of The Notice Under Section 143(2) Of The Act & The Assessment Thereunder: 1.A) On The Facts & In The Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) [Cit (A)] Erred In Upholding The Assessment For The Assessment Year 2006-07 Framed By The Learned Assessing Officer Without Complying With The Relevant Provisions Of The Law. B) It Is Respectfully Submitted That No Notice Under Section 143(2) Of The Act Was Served On The Appellant Within The Time Limits Prescribed Under Section 143(2) Of The Act. Accordingly, The Learned Assessing Officer Had No Jurisdiction To Proceed With Scrutiny Assessment Under Section 143(3) Of The Act. Thus, The Assessment Is Bad In Law & Deserves To Be Quashed & Struck Down As Null & Void. In View Of The Above, The Appellant Prays That The Assessment Be Set Aside As Bad In Law & Struck Down As Null & Void.

For Appellant: Shri Subhash Chhajed, ARFor Respondent: Ms. Pradnya Gholap, Sr. DR

Section 143(2)Section 143(3)Section 144Section 254(1)Section 54FSection 69

circumstances of the case and in law, the Ld. ADDL/JCIT (Appeals), AGRA erred in upholding the addition of Rs. 32,80,000/- as unexplained investment u/s 69 of the I. T. Act 1961 whereas the same was added as Long-Term Capital Gain by the Ld. AO on sale ... circumstances of the case and in law the Ld. ADDL/JCIT (Appeals), AGRA erred in treating the investment of Rs. 32,80,000/- as unexplained investment u/s 69 of the Act despite the fact that the same has been recorded in the books of accounts maintained by the Assessee. EXEMPTION

Hariram Hospital, Alwar vs. PCIT, Alwar

In the result, the appeal of the assessee is allowed

ITA 1535/JPR/2024[2019-20]Status: DisposedITAT Jaipur17 Apr 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1535/JPR/2024 निर्धारणवर्ष / Assessment Year: 2019-20 Hariram Hospital Bye Pass Road Hariram Hospital Bhiwadi, Alwar – 310 019 (Raj) बनाम Vs. The Pr.CIT (Central) Jaipur प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAFFH 5746 M अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : Shri Himanshu Goyal, CA राजस्व की ओरसे /Revenue by: Mrs. Alka Gautam, CIT-DR सुनवाई की तारीख / Da

For Appellant: Shri Himanshu Goyal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR

Section 143(3)Section 263

completed on 27-09-2021 at assessed income of Rs.40,80,265 (after making addition of Rs.31,16,355/- on account of unexplained investment u/s 69B of the Act). 3.2 The ld. PCIT on examination of examination of assessment records observed that the AO had not examined the veracity ... assessee was assessed at Rs. 40,80,265/-. The significant addition of Rs 31,16,355 was made on account of an unexplained investment under Section 69B towards the construction of the hospital building That in response to the initial notice dated 06.09.2022 initiating revision proceedings under Section

Satish Kumar Agarwal, Jaipur vs. DCIT, Jaipur

In the result the appeal of the assessee is allowed

ITA 1170/JPR/2024[2013-14]Status: DisposedITAT Jaipur17 Apr 2025AY 2013-14

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Tarun Mittal, C.A., Ld. ARFor Respondent: Mr. Arvind Kumar, CIT, Ld. DR

Section 115BSection 132(1)Section 132(4)Section 142(1)Section 143(3)Section 250

that the assessee can take the benefit of reduction in the prevailing price of the gold against the surrendered income on account of unexplained investment in the stock. Since this issue was not considered by the authorities below as the AO disallowed the claim of the assessee by placing reliance

M/S. Dholera Realcon LLP, Ahmedabad vs. The ITO, Ward-3(2)(1), Ahmedabad

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

ITA 1545/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Apr 2025AY 2017-18

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Section 115BSection 133(6)Section 147Section 148Section 271ASection 68Section 69

order confirming the action of Income Tax Officer, NFAC(Assessment)-Delhi, whereby confirmed the addition of Rs. 67,85,994/-made on account of unexplained investment u/s 69 of the IT Act made during the year under consideration. 3. The Ld. Commissioner of Income Tax (E-Appeals) (Hereinafter referred ... submitted by the appellant in right perspective and passed the assessment order by making huge addition of capital/unsecured loan introduced during the year as unexplained investment. I.T.A No. 1545/Ahd/2024 A.Y. 2017-18 Page No 3 M/s. Dholera Realcon LLP vs. ITO 7. The Ld. Assessing Authority has erred in charging

Rekha Yadav, Gurgaon vs. ITO Ward-5(1), New Delhi

In the result, assessee’s appeal is allowed for statistical purposes

ITA 336/DEL/2025[2012-13]Status: DisposedITAT Delhi17 Apr 2025AY 2012-13

Bench: DELHI BENCH “SMC”: NEW DELHI Ms. MADHUMITA ROY (Judicial Member)

Section 144Section 147Section 69Section 69A

assessment at Rs. 42,49,077/- by adding Rs. 8,97,217/- on account of unexplained cash credits and Rs. 27,50,000/- as unexplained investment in house property u/s 69A of the Act. Aggrieved by the said order the assessee preferred appeal before the learned ... under consideration the assessing officer had reasons to believe that the assessee had made unexplained cash deposits of Rs. 08,97,217/- and made unexplained investment in purchase of property of Rs. 27,50,000/-. As the assessee failed to reply and provide any required details. Hence, the A.O. completed

Shyamsunder Bang, New Delhi vs. ACIT Central Circel 8, New Delhi

In the result, the Appeal of the Assessee is allowed

ITA 1887/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Apr 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singhshyam Sunder Bang Vs. Acit M-6, Greater Kailsah Part Central Circle 8 2, New Delhi Ara Centre, Jhandewalan Pan: Aafpb2321L Extension, New Delhi Appellant Respondent Assessee By Sh. Rohit Tiwari, Adv & Ms. Tanya, Adv Revenue By Ms. Jaya Chaudhary, Cit(Dr) Date Of Hearing 27/02/2025 Date Of Pronouncement 17/04/2025 Order

Section 132Section 139(1)Section 143(2)Section 153CSection 154Section 69B

from the premises ofGurvinder Singh Duggal, an addition has been madein the hands of the Assessee u/s 69B of the Act on account of unexplained investment to the tune of Rs. 30,00,000/- by way of the assessment order dated on 31/12/2022 passed u/s 153C of the Act. Aggrieved ... material available on record. The Ld. A.O. while making the addition of Rs. 30,00,000/-, observed that the Assessee had made an unexplained investment of Rs. 30,00,000/-in a property transaction which was not reflected in the books of accounts and while doing

K.V. Sankar (HUF), Cuddalore vs. ITO, Ward-4, Cuddalore

In the result, the appeal of the assessee is allowed

ITA 312/CHNY/2025[2011-12]Status: DisposedITAT Chennai17 Apr 2025AY 2011-12

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 312/Chny/2025 िनधा"रण वष" / Assessment Year: 2011-12 M/S. K.V. Sankar (Huf), The Income Tax Officer, 93,V.O.C Street, V. Ward-4, Panruti, Cuddalore – 607 106. Cuddalore – 607 001. [Pan: Aaghk 7331E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms.T.V. Muthu Abirami, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 19.03.2025 घोषणा क" तार"ख/Date Of Pronouncement : 17.04.2025 आदेश /O R D E R

For Appellant: Ms.T.V. Muthu Abirami, AdvocateFor Respondent: Shri A. Sasikumar, CIT

Section 115BSection 69

income. 12. For that the Commissioner of Income Tax (Appeals) erred in confirming the addition of the cash deposits made by the appellant as unexplained investment u/s.69. The cash deposits are appellant's business receipts through sales made to his customers. 13. For that the Commissioner of Income Tax (Appeals ... Income Tax (Appeals) failed to appreciate that merely because cash is deposited into the bank account of the appellant, it cannot be added as unexplained investment u/s.69. The bank statement cannot constitute as appellant's books. :-3-: ITA. No:312/Chny/2025 15. For that the Commissioner of Income Tax (Appeals) failed

Rahul Jesmin Seth, Chennai vs. ITO, Ncw-22(5), Tambaram

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

ITA 307/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकर अपीलसं./Ita No.: 307/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Rahul Jesmin Seth, Vs. The Income Tax Officer, Flat No. Ef, 15Th Floor, Sapphire Non Corporate Ward –22(5), Block K, Olympia Opaline No. 33, Tambaram, Chennai. Omr Rajiv Gandhi Salai, Navallur, Chennai 603 103. [Pan: Bhsps-7395-L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Dated 23.12.2024 Pertains To The Assessment Year 2017-18. 2. The Assessee Raised 18 Grounds Of Appeal, Amongst Which, Besides Challenging The Exparte Order Of The Ld. Cit(A), The Assessee Also Agitated That The Ld. Cit(A) Is Not Justified In Confirming The Additions Of ₹.27,31,000/- Being The Cash Deposits Made In Sbns During The Demonetization Period

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri A. Sasi Kumar, CIT

Section 10Section 10(14)(ii)Section 133(6)Section 139(1)Section 142(1)Section 144Section 17(2)Section 250Section 69

cash deposits made during the demonetization period of ₹.27,31,000/-, the Assessing :-4-: ITA. No: 307/Chny/2025 Officer treated the same as unexplained investments under section 69 of the Act and completed the assessment under section 144 of the Act dated 18.12.2019 by assessing total taxable income of the assessee

Income Tax Officer -42(1)(3), Mumbai, Kautilya Bhavan, Bkc, Bandra vs. Krishna Deep Builders, Mumbai

In the result, the appeal filed by the assessee is allowed and the appeal filed by the revenue is dismissed

ITA 6240/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Apr 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Smt. Renu Jauhri, Am Krishna Deep Builders Ito Ward – 42(1)(3) B/203, 2Nd Floor, Goyal Shopping Arcade, Room No. 715, Kautilya Bhavan, C- Opp. Railway Station, S. V. Road, Vs. 41 To C-43, G Block, Bandra Kurla Borivali, West, Mumbai – 400092. Complex, Bandra (East), Mumbai – 400051. Pan/Gir No. Aaafk375Q (Assessee) : (Respondent) Ito Ward – 42(1)(3) Krishna Deep Builders Room No. 715, Kautilya Bhavan, C-41 To B/203, 2Nd Floor, Goyal Shopping C-43, G Block, Bandra Kurla Complex, Vs. Arcade, Opp. Railway Station, S. V. Bandra (East), Mumbai – 400051. Road, Borivali, West, Mumbai – 400092. Pan/Gir No. Aaafk375Q (Assessee) : (Respondent) : Shri. Ajay Singh Assessee By Respondent By : Shri. Hemanshu Joshi (Sr. Dr) Date Of Hearing : 20.01.2025 Date Of Pronouncement : 17.04.2025 O R D E R Per Kavitha Rajagopal, J M: These Are Cross Appeals Filed By The Revenue & The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals) Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The

For Respondent: Shri. Hemanshu Joshi (Sr. DR)

Section 144Section 147Section 148Section 148ASection 250Section 56(2)Section 56(2)(vi)Section 56(2)(vii)Section 69Section 69A

reopening of the assessment u/s. 144 of the Act. The revenue has challenged the deletion of addition of Rs. 87,93,925/- being the unexplained investment u/s. 69 of the Act in respect of the purchase of immovable property, where it is alleged that the assessee is said to have ... sale consideration and Rs. ITA No. 5768 &6240/Mum/2024 (A.Y. 2017-18) Krishna Deep Builders 87,93,925/- towards the addition on account of unexplained investment u/s. 69 r.w.s. 115BBE of the Act. 4. Aggrieved the assessee was in appeal before the first appellate authority, challenging the impugned addition along with

Krishna Deep Builders, Mumbai vs. Income Tax Officer Ward-42(1)(3), Mumbai

In the result, the appeal filed by the assessee is allowed and the appeal filed by the revenue is dismissed

ITA 5768/MUM/2024[2017-18]Status: DisposedITAT Mumbai17 Apr 2025AY 2017-18

For Respondent: Shri. Hemanshu Joshi (Sr. DR)

Section 144Section 147Section 148Section 148ASection 250Section 56(2)Section 56(2)(vi)Section 56(2)(vii)Section 69Section 69A

Husna Begam, Yamuna Nagar, Haryana vs. Income Tax Officer, Ward-2, Yamuna Nagar, Haryana

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

ITA 970/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh16 Apr 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Adj. Application (Rejected)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr .DR

Section 142(1)Section 144Section 147Section 148

determined at Rs. 1,03,09,200/- against a returned income of NIL, with the entire amount being added on account of unexplained investment in immovable property. 3.2 The assessee had originally filed an appeal before the Ld. CIT(A) against the order of the Assessing Officer (AO), wherein ... addition of Rs. 1,03,09,200/- was made under Section 69 of the Income-tax Act, 1961, treating the same as unexplained investment in immovable property. The Ld. CIT(A) dismissed the appeal and upheld the addition, observing that the assessee had failed to respond to multiple statutory notices

Income Tax Officer Ward 3(1), Ludhiana vs. Gaurav Kumar, Ludhiana

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

ITA 412/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh16 Apr 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT

Section 115BSection 133(6)Section 145(3)Section 69

fictitious entries and lack of corroborative evidence. The cash deposits of Rs. 1,78,96,190/- during demonetization were treated as unexplained investments under Section 69, added to his taxable income. This amount, taxed at 60% under Section 115BBE, raised the total assessed income to Rs.1 ... books of accounts under Section 145(3) due to these inconsistencies and lack of verifiable details, and that Section 69 was appropriately invoked for unexplained investments, with Section 115BBE applicable to tax such income at a higher rate. Thus the Ld. DR submitted that the addition and penalty should

Mahesh Yadav Alam, Secunderabad vs. ITO., Ward-15(1), Hyderabad

In the result, both the captioned appeals are disposed of in terms of the aforesaid observations

ITA 406/HYD/2025[2015-16]Status: DisposedITAT Hyderabad16 Apr 2025AY 2015-16

Bench: Us:

Section 144Section 147Section 148Section 149Section 234ASection 69

Income Tax Act, 1961, being time-barred as per section 149 of the Act. 3. Confirming the addition of Rs. 9,65,000/- as unexplained investment under section 69 of the Act. 4. Computing the interest under section 234A, 234B and 234C of the Income-Tax Act, 1961.” 3. Shri

Mahesh Yadav Alam, Secunderabad vs. ITO., Ward-15(1), Hyderabad

In the result, both the captioned appeals are disposed of in

ITA 405/HYD/2025[2013-14]Status: DisposedITAT Hyderabad16 Apr 2025AY 2013-14

Section 144Section 147Section 148Section 149Section 234ASection 69

Income Tax Act, 1961, being time-barred as per section 149 of the Act. 3. Confirming the addition of Rs.9,65,000/- as unexplained investment under section 69 of the Act. 4. Computing the interest under section 234A, 234B and 234C of the Income-Tax Act, 1961.” 3. Shri Pankaj

Ullahas Nandini Udyog Pvt. Ltd., Howrah vs. ITO, Circle-13(1), Kolkata

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

ITA 177/KOL/2025[2014-15]Status: DisposedITAT Kolkata16 Apr 2025AY 2014-15

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 144Section 147Section 148Section 250Section 69

notice u/s 148 was issued. b) Assessment was completed u/s 147/144 on 02/12.2019 by making addition of Rs. 3,85,00,000/- as unexplained investment u/s 69 of the Act. c) Appellant filed appeal before Ld. CIT(A) on 31.01.2020 against the above addition. d) Ld. CIT(A)-NFAC

Ullahas Nandini Udyog Pvt. Ltd., Howrah vs. DCIT, Circlr-13(1), Kolkata

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

ITA 176/KOL/2025[2012-13]Status: DisposedITAT Kolkata16 Apr 2025AY 2012-13

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 144Section 147Section 148Section 250Section 69

Sudam Sahoo, Purba Medinipore vs. ITO, Ward 27(1), Haldia

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

ITA 144/KOL/2025[2020-21]Status: DisposedITAT Kolkata16 Apr 2025AY 2020-21

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 115BSection 56(2)(x)Section 68Section 69

requested to show cause as to why the entire investment in immovable properties of Rs. 1,91,00,000/- should not be treated as unexplained investment u/s 69 read with Section 115BBE of the Act. The assessee has been noticed but there was no reply from the side

Om Processors Private Limited, K-3, Textiles Colony Ludhiana (East), Millerganj, Ludhiana, Punjab vs. DCIT, Central Circle-3, Ludhiana, Punjab

In the result, appeal of the Assessee is allowed

ITA 758/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh11 Apr 2025AY 2017-2018

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, DR

Section 115BSection 143(1)Section 143(2)Section 148Section 68Section 69Section 69B

surrendered certain amount on account of addition made to factory building Assessing Officer was of view that said amount was to be considered as unexplained investment under section 69B and was subject to taxation as per provisions of section 115BBE - It was noted that assessee had treated said surrendered amount ... surrendered excess stock, cash and receivables, stating that same was to be taxed as business income - Assessing Officer, however, treated said surrendered amount as unexplained investment under sections 69A and 69B and charged same to tax as per provisions of section 115BBE - Whether since during survey proceedings, assesse was confronted