“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

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 548/CHNY/2024[2014-15]Status: DisposedITAT Chennai11 Mar 2025AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT

Section 153ASection 250Section 56

assessment year 2018-19, the AO has made addition of Rs.1,50,00,000/- u/s.69 of the Act, as unexplained investment. In the search conducted in the premises of the assessee, there was no incriminating material to disclose that assessee had advanced loan outside books of account to Shri O.Arumugasamy

Smt. Amandeep Kaur W/O Sh. Bhupinder Singh, Nawanshahr vs. Income Tax Officer Ward, Nawanshahar

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

ITA 263/ASR/2024[2013-14]Status: DisposedITAT Amritsar10 Mar 2025AY 2013-14

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 263/Asr/2024 निर्धारण वर्ा / Assessment Year : 2013-14 Amandeep Kaur, बनाम The Ito, W/O Shri Bhupinder Singh, Ward, Moh Rajan, Rahon Town, Nawanshahr District Nawanshahr स्थधयी लेखध सं./Pan No: Avfps3980C अपीलधथी/Appellant प्रत्यथी/Respondent ( Virtual Hearing ) निर्धाररती की ओर से/Assessee By : Shri Rakesh Joshi, Advocate रधजस्व की ओर से/ Revenue By : Shri Davinder Pal Singh, Sr. Dr सुिवधई की तधरीख/Date Of Hearing : 16.12.2024 उदघोर्णध की तधरीख/Date Of Pronouncement : 10.03.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 20.05.2024 Passed By Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi On The Following Grounds: 2. Grounds Of Appeal Are As Under:-

For Appellant: Shri Rakesh Joshi, AdvocateFor Respondent: Shri Davinder Pal Singh, Sr. DR

Section 80

Commissioner of Income Tax (Appeals)-NFAC, Delhi has further erred in law & facts of the case in confirming the investment of insurance amount as unexplained investment.. 3. That the Ld. Commissioner of Income Tax (Appeals) NFAC, Delhi Further also erred in law & facts of the case in further confirming

Assistant Commissioner of Income Tax Central Circle-I, Jalandhar vs. Shrimati Jatinder Kaur Alias Amrita, Jalandhar

In the result the appeal of the Revenue is dismissed

ITA 146/ASR/2022[2017-18]Status: DisposedITAT Amritsar10 Mar 2025AY 2017-18

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 146/Asr/2022 निर्धारण वर्ा / Assessment Year : 2017-18 The Acit, बनाम Smt. Jatinder Kaur Alias Central Circle-1, Amrita, Jalandhar 326A, Guru Teg Bahadur Nagar, Jalandhar स्थधयी लेखध सं./Pan No: Aalpa2363B अपीलधथी/Appellant प्रत्यथी/Respondent ( Hybrid Hearing ) निर्धाररती की ओर से/Assessee By : Shri S. S. Kalra, Ca रधजस्व की ओर से/ Revenue By : Shri Davinder Pal Singh, Sr. Dr सुिवधई की तधरीख/Date Of Hearing : 19.12.2024 उदघोर्णध की तधरीख/Date Of Pronouncement : 10.03.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 21.04.2022 Passed By Ld. Commissioner Of Income Tax (Appeals)-5, Ludhiana [ Herein Referred To As ‘Cit(A)’ ]On The Following Grounds:

For Appellant: Shri S. S. Kalra, CAFor Respondent: Shri Davinder Pal Singh, Sr. DR

Section 254Section 69

circumstances of the case, the Ld. CIT(A) has erred in deleting the addition of Rs.71,73,954/- on account of unexplained investment u/s 69 of the Act which was transferred in the account of assessee through foreign remittance by her father during the year under consideration? 2. Whether

Income Tax Officer, Ward 1(3)(1), Surat vs. Dhiraj Sons Super Market, Surat

In the result, ground No. 2 is also dismissed

ITA 553/SRT/2024[2017-18]Status: DisposedITAT Surat10 Mar 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 553/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Income Tax Officer, Ward- Dhiraj Sons Super Market, Surat 1(3)(1), Surat, Room No.203, C/O Dhiraj Sons Super Store, बनाम Income Tax Office, Anavil Samarth Sarathi Apartment, Parle, Vs Building, Adajan, Surat-395 009 Point, Surat-395 007 [Pan : Aaifd 6720 A] अपीलाथ"/Appellant ""थ" /Respondent

Section 143(3)Section 145(3)Section 254(1)Section 69A

ledger, bills and not explained source of funds. Hence, in absence of any reply, the AO also added Rs.67,99,486/- on account of unexplained investment in fixed asset. The AO passed assessment order under section 143(3) of the Act on 21.12.2019. 3. Aggrieved by the addition made ... hence, section 69A is not 7 Dhiraj Sons Super Market, Surat applicable. On the basis of such observation, Ld.CIT(A) deleted the addition of unexplained investment. Aggrieved by the order of Ld.CIT(A), the revenue has filed present appeal before this Tribunal. 7. We have heard the submission

Kailash Chand, Jaipur vs. ITO Ward, Behror

In the result, the appeal of the assessee is allowed

ITA 565/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Mar 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Judicial Member)

For Appellant: Sh. Mahendra Gargieya, Adv. &For Respondent: Sh. Dinesh Badgujar, Addl. CIT

Section 142(1)Section 144Section 144BSection 147Section 148Section 234A

been made. There is no allegation that there was no source behind the purchase of the truck (fixed assets) and that it was unexplained investment. In view of these admitted facts, it is beyond one's understanding as to how and under what provision, any addition to the declared income

ACIT, Central Circle, Alwar vs. Sh. Tara Chand Gupta, Alwar

In the result the appeal filed by the revenue in ITA no

ITA 514/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA. Nos.447 to 449/JP/2024 निर्धारण वर्ष / Assessment Years : 2015-16 to 2017-18 Shri Tarachand Gupta 9 Keshav Nagar Sch 13, Alwar बनाम ACIT, Vs. Central Circle, Alwar स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AAYPC 5777 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent आयकर अपील सं./ITA. No. 514/JP/2024 निर्धारण वर्ष / Assessment Year : 2017-18 ACIT, Central Circle, Alwar बनाम Shri Tarachand Gupta 9 Kesh

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR a

Section 143(3)Section 68Section 69C

circumstances of the case, the Ld. CIT(A) is justified in deleting the addition of Rs.65,02,600/- made on account of unexplained investment in cash loans on the ground that unaccounted receipts have been taxed earlier and the assesse had funds available for advance of Rs.65,02,600/- made ... total income of the assessee as per provisions of section 69C r.w.s. 115BBE of the Act. 4.6 The other addition of as unexplained investment for Rs. 31,65,500/- u/s. 69 was made and addition u/s. 56(2)(vii)(b)(ii) for Rs. 1,46,933/- was made which were

Sh. Tarachand Gupta, Alwar vs. ACIT, Central Circle, Alwar

In the result the appeal filed by the revenue in ITA no

ITA 449/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA. Nos.447 to 449/JP/2024 निर्धारण वर्ष / Assessment Years : 2015-16 to 2017-18 Shri Tarachand Gupta 9 Keshav Nagar Sch 13, Alwar बनाम Vs. ACIT, Central Circle, Alwar स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AAYPC 5777 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent आयकर अपील सं./ITA. No. 514/JP/2024 निर्धारण वर्ष / Assessment Year : 2017-18 ACIT, Central Circle, Alwar बनाम Shri Tarachand Gupta 9 Ke

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR a

Section 143(3)Section 68Section 69C

Sh. Tarachand Gupta, Alwar vs. ACIT, Central Circle, Alwar

In the result the appeal filed by the revenue in ITA no

ITA 448/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 143(3)Section 68Section 69C

circumstances of the case, the Ld. CIT(A) is justified in deleting the addition of Rs.65,02,600/- made on account of unexplained investment in cash loans on the ground that unaccounted receipts have been taxed earlier and the assesse had funds available for advance of Rs.65,02,600/- made ... made in the total income of the assessee as per provisions of section 69C r.w.s.115BBE of the Act. 4.6 The other addition of as unexplained investment for Rs. 31,65,500/- u/s.69 was made and addition u/s.56(2)(vii)(b)(ii) for Rs.1,46,933/- was made which were

Sh. Tarachand Gupta, Alwar vs. ACIT, Central Circle, Alwar

In the result the appeal filed by the revenue in ITA no

ITA 447/JPR/2024[2015-16]Status: DisposedITAT Jaipur10 Mar 2025AY 2015-16

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR

Section 143(3)Section 68Section 69C

circumstances of the case, the Ld. CIT(A) is justified in deleting the addition of Rs.65,02,600/- made on account of unexplained investment in cash loans on the ground that unaccounted receipts have been taxed earlier and the assesse had funds available for advance of Rs.65,02,600/- made ... made in the total income of the assessee as per provisions of section 69C r.w.s.115BBE of the Act. 4.6 The other addition of as unexplained investment for Rs. 31,65,500/- u/s.69 was made and addition u/s.56(2)(vii)(b)(ii) for Rs.1,46,933/- was made which were

Sh. Trilok Chand Sain, Dausa vs. ITO, Ward-1(2), Alwar

ITA 1266/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C Parwal, FCAFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 147Section 148Section 148ASection 271(1)(c)

NFAC has erred on facts and in law in confirming the addition of Rs.42,50,250/- made by AO on account of unexplained investment in purchase of land by not appreciating that the land under consideration is owned by Sh. Purushottam Bairwa, investment was made by him from ... Trilok Chand Sain he made the registry in the name Shri Purushottam Bairwa, therefore, it is clear that Shri Trilok Chand Sain has made unexplained investment in this land. Further, Shri Trilok Chand Sain has said in his reply that he has purchased the land in his personal capacity

Sh. Trilok Chand Sain, Dausa vs. ITO, Ward-1(2), Alwar

ITA 1265/JPR/2024[2016-17]Status: DisposedITAT Jaipur10 Mar 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C Parwal, FCAFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 147Section 148Section 148ASection 271(1)(c)

Kalyan Sahai Sharma, Jaipur vs. ITO Ward 7(4), Jaipur, Sidh Nath Bhawan

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

ITA 1096/JPR/2024[2012-13]Status: DisposedITAT Jaipur10 Mar 2025AY 2012-13

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalkalyan Sahai Sharma, New Kothi, Pokhrivyawala Chop, Jaipur 303805 Pan No.: Cqyps6457H ...... Appellant Vs. Income Tax Officer Ward-7(2), Jaipur, Sidh Nath Bhawan ...... Respondent

For Appellant: Mr. R. S. Jaju, Adv., Ld. ARFor Respondent: Mr.Gautam Singh Choudhary, JCIT- Ld. DR

Section 139Section 144Section 148Section 250Section 282

case of the assessee was assessed u/s. 144 r.w.s. 147 of the Act and Rs. 45,23,452/- were added back as unexplained investment. The assessee being aggrieved with the same preferred an appeal before the Ld. CIT (A), who in turn dismissed the appeal of the assessee and confirmed

Income Tax Officer, Ward-6(1), Hyderabad vs. Hemanth Kantamneni, Hyfderabad

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

ITA 1307/HYD/2024[2017-18]Status: DisposedITAT Hyderabad10 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Rajesh Vaishnav, C.AFor Respondent: Shri Srinath Sadanala, SR-DR

Section 133(6)Section 143(2)Section 144Section 69Section 69A

which Rs.69,64,563/- was funded through loan from PNB Housing Finance Limited. Accordingly, the balance amount of Rs.66,25,397/- was considered as unexplained investment u/s.69 of the Act. The Ld. AO further observed that, the assessee had incurred expenditure of Rs.7,47,378/- towards payment of stamp duty ... registration charges, which was also not explained. Accordingly, the Ld. AO added this amount also to the unexplained investment u/s.69 of the Act. Hence, the Ld. AO made a total addition of Rs.73,72,775/- u/s.69 of the Act. In addition, the Ld. AO found that during the period

Govind Patel, Navi Mumbai vs. ITO Ward 28(1)(1), Navi Mumbai

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

ITA 277/MUM/2025[2017 - 18]Status: DisposedITAT Mumbai10 Mar 2025

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Roshan Ochani, A/RFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R

Section 148Section 151Section 270ASection 56(2)(vii)Section 69Section 69A

SECTION 69 R. W.S 115BBE THAT, AO is erred in law and on facts allegedly making addition on account of unexplained investments on purchase of immovable property u/s. 69 r.w.s. 115BB amounting to Rs. 1,25,641,00/- 5. SECTION 69 R.W.S. 115BBE THAT, AO is erred ... facts allegedly making addition on account of unexplained investments on purchase of bonds/debentures under section 69 r.w.s.115BBE amounting to Rs. Rs.5,87,50,000/- 6. SECTION 69A R.W.S. 115BBE THAT, AO is erred in law and on facts allegedly making addition on account of unexplained money on cash deposit

Nh Securities Limited, Mumbai vs. JCIT (OSD) Central Circle 7(1), Mumbai

In the result, the appeal is allowed

ITA 155/MUM/2025[1999-2000]Status: DisposedITAT Mumbai10 Mar 2025AY 1999-2000

Bench: Justice (Retd.) C.V. Bhadang & Shri B.R. Baskaran: A.Y. : 1999-2000

For Appellant: Shri Rajiv KhandelwalFor Respondent: Shri Alok Kumar

Section 10(33)Section 271(1)(c)Section 68Section 69

Rs.1,37,38,650/-. The Assessing Officer had made the following additions :- 2 N H Securities Ltd. Sr. No. Description Amount (Rs.) 1 Unexplained investment u/s 69 3,97,57,29,214 2 Undisclosed profit 5,62,58,741 3 Unexplained Cash Credit ... Dividend u/s 10(33) 27,66,827 5 Unexplained investment u/s 69 56,000 3. A further perusal of the impugned order shows that out of the quantum addition of Rs.14.84 crores as unexplained cash credit under Section 68 of the Act, only an addition to the extent of Rs.2

Prafula Kamlesh Thakkar, Ahmedabad vs. The Income Tax Officer, Ward-2, Surendranagar

ITA 808/RJT/2024[2019-20]Status: DisposedITAT Rajkot07 Mar 2025AY 2019-20

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.808/Rjt/2024 "नधा"रणवष" / Assessment Year: (2019-20) (Hybrid Hearing) Prafula Kamlesh Thakkar Income Tax Officer Ward 2, Vs. C/O. M S Chhajed & Co. Ca, Surendranagar 363001 “Kamal Shanti” Nr Sardar Patel Statue, Ahmedabad 380014 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bmfpt2701K (Appellant) (Respondent) Appellant By : Ms. Preyasi Tatad, Ld. Ar Respondent By : Shri Sanjay Pungalia , Ld Cit(Dr) Date Of Hearing : 03/03 /2025 Date Of Pronouncement : 07/ 03/2025

For Appellant: Ms. Preyasi tatad, Ld. ARFor Respondent: Shri Sanjay Pungalia , Ld CIT(DR)

Section 142(1)Section 147Section 148Section 148ASection 69

Subsequently the Ld. AO has issued SCN dated 14.02.2024 proposing addition to the income of appellant on the basis of unexplained investment during the year U/S 69 of the Act. In response to SCN appellant has filed detailed reply vide letter dated 19.02.2024. Property was purchased ... asked by the Ld. AO The Ld. AO has passed the Assessment order U/S 147 r.w.s 144 of the Act by making addition as unexplained investment. The Ld.A.O. has passed order U/S 147 r.w.s 144 of the Act dated 25.02.2024 making addition

Hareshbhai Arjundas Gurbani, Jamnagar vs. The Income Tax Officer, WD 2(10), Jamnagar

ITA 611/RJT/2024[2013-14]Status: DisposedITAT Rajkot07 Mar 2025AY 2013-14

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.611/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Hareshbhai Arjundas Gurbani Aaykar Bhawan, Vs. 109/110 City Aarced, Nr Dsp Jamnagar Bunglow, Tin Batti, Jamnagar 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqspg3832M (Appellant) (Respondent) Appellant By : Shri Suresh Tejwani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav , Ld. Sr. (Dr) Date Of Hearing : 03/03 /2025 Date Of Pronouncement : 07/ 03/2025 आदेश / O R D E R Per Dinesh Mohan Sinha Jm;

For Appellant: Shri Suresh Tejwani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav , Ld. Sr. (DR)

Section 139Section 139(1)Section 142(1)Section 144Section 148Section 69A

argument, I opined that there is no infirmity or illegality in initiating proceedings and making addition of Rs.10,56,500/- is treated as unexplained investment of appellant within the meaning of section 69A of the Act.” In the result, the appeal of the assessee is hereby dismissed. That the assessee ... order that no infirmity or illegally was found in the order of Ld AO and confirmed the action of the AO about the unexplained investment u/s 69A of the Act. We further note that during the course of assessment proceedings the Ld AO has issued notices

Galaxy International Overseas, Dhuva, Wankaner vs. Income Tax Officer, Ward-1, Morbi

ITA 54/RJT/2024[2014-15]Status: DisposedITAT Rajkot07 Mar 2025AY 2014-15

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 54/Rjt/2024 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Galaxy International Overseas Income Tax Officer, Vs. C/O. Sarda & Sarda, Cas, Ward – 1, 1St Floor, “Sakar”, Shakti Chambers, Nh27, Anand Dr. Radhakrishnan Road, Nagar, Opp. Rajkumar College, Morbi - 363642 Rajkot – 360001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfg6749C (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) Date Of Hearing : 17/12/2024 Date Of Pronouncement : 07/03/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 143(1)Section 143(3)Section 263Section 36(1)(iii)Section 44A

order that no infirmity or illegally was found in the order of Ld AO and confirmed the action of the AO about the unexplained investment u/s 69A of the Act.Besides this the Ld CIT(A) has dismissed the appeal of the assessee stating that assessee is not willing to pursue

Gurram Padmavathi, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 511/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2019-20

Bench: Shri K Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. Nos. 510 & 511/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2019-20) Gurram Padmavathi, Vs. Income Tax Officer, Visakhapatnam. Ward-2(5), Pan: Ahgpg4966L Visakhapatnam. (अपीलधथी/ Appellant) (प्रत्यथी/ Respondent) अपीलधथी की ओर से/ Assessee By : Sri Gvn Hari, Ar प्रत्यधथी की ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 147Section 148Section 271ASection 69

nature and sources of purchase of the property, the amount of Rs. 14,34,000/- involved in the purchase of property was treated as unexplained investment and accordingly made the addition U/s. 69 of the Act and passed the assessment order dated 3 25/03/2022 U/s. 147 r.w.s 144B

Gurram Padmavathi, Visakhapatnam vs. Income Tax Officer, Ward-2(5), Visakhapatnam

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

ITA 510/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam07 Mar 2025AY 2019-20

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 147Section 148Section 271ASection 69