“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

P.Shanmugasundaram (HUF), Erode vs. DCIT Central Circle 3(I/C), Coimbatore

In the result, the appeal stands partly allowed for statistical purposes

ITA 1997/CHNY/2024[2012-13]Status: DisposedITAT Chennai24 Feb 2025AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1.आयकरअपील सं. / Ita No.1995/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2012-13) Shri Shanmugasundaram Umashankar Dcit बनाम/ 531, Easwaran Koil Street, Central Circle-3(I/C) Vs. Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpu-0364-C (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2.आयकरअपील सं. / Ita No.1996/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2012-13) Shri Shanmugasundaram Karthikeyan Dcit बनाम/ 531, Easwaran Koil Street, Central Circle-3(I/C) Vs. Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aeepk-4137-L (अपीलाथ"/Appellant) : (" थ" / Respondent) & 3.आयकरअपील सं. / Ita No.1997/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2012-13) Shri P. Shanmugasundaram (Huf) Dcit बनाम/ 531, Easwaran Koil Street, Central Circle-3(I/C) Vs. Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aachp-1597-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Ms. T.V. Muthu Abirami (Advocate)- Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 03-12-2024 घोषणा की तारीख /Date Of Pronouncement : 24-02-2025

For Appellant: Ms. T.V. Muthu Abirami (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR

Section 143(3)Section 234B

around Rs.916.47 Lacs was generated by the firm in the matter of 7 months to make payment over and above registered value. Therefore, unexplained investment for purchase of the property would have been contributed by the partners only and therefore, the same was to be assessed in the hands

Shanmugasundaram Karthikeyan, Erode vs. DCIT Central Circle - 3(I/C), Coimbatore

In the result, the appeal stands partly allowed for statistical purposes

ITA 1996/CHNY/2024[2012-13]Status: DisposedITAT Chennai24 Feb 2025AY 2012-13

For Appellant: Ms. T.V. Muthu Abirami (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR

Section 143(3)Section 234B

Shanmugasundaram Umashankar, Erode vs. DCIT Central Circle 3(I/C), Coimbatore

In the result, the appeal stands partly allowed for statistical purposes

ITA 1995/CHNY/2024[2012-13]Status: DisposedITAT Chennai24 Feb 2025AY 2012-13

For Appellant: Ms. T.V. Muthu Abirami (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR

Section 143(3)Section 234B

DCIT, Central Circle 2(3), Chennai vs. Vavipalayam Selvaraju Thennerasu, Namakkal

In the result, both the appeals stand dismissed

ITA 1153/CHNY/2024[2015-16]Status: DisposedITAT Chennai24 Feb 2025AY 2015-16

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1152/Chny/2024 (िनधा*रण वष* / Assessment Year: 2015-16) Dcit Smt. Amutha Thennarasu बनाम/ Central Circle-2(3) 2/352, Vavipalayam, Vs. Chennai. Kollaram P.O., Namakkal -637 201. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abypa-7011-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं. / Ita No.1153/Chny/2024 (िनधा*रण वष* / Assessment Year: 2015-16) Dcit Shri Vavipalayam Selvaraju Thennarasu बनाम/ Central Circle-2(3) 2/352, Vavipalayam, Vs. Chennai. Kollaram P.O, Namakkal -637 201. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abfpt-8530-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Clement Ramesh Kumar (Cit) -Ld. Dr " थ"कीओरसे/Respondent By : Shri M.V. Swaroop (Advocate) - Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 08-01-2025 घोषणाकीतारीख /Date Of Pronouncement : 24-02-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri Clement Ramesh Kumar (CIT) -Ld. DRFor Respondent: Shri M.V. Swaroop (Advocate) - Ld. AR

Section 132Section 143

erroneous on facts of the case and in law. 2 The Ld.CIT(A) erred in deleting the addition Rs.10,39,38,614/- made towards unexplained investment in the purchase of property, evidenced by the entries found in material seized in the locker belonging to third party. 2.1. The Ld.CIT ... deed, hence the same cannot be considered as dumb documents. As is evident, the sole issue that arises for our consideration is addition of unexplained investment. 2. The Ld. CIT-DR advanced arguments and submitted that the impugned addition is based on certain documents as found from the locker

DCIT, Central Circle 2(3), Chennai vs. Amutha Thennarasu, Namakkal

In the result, both the appeals stand dismissed

ITA 1152/CHNY/2024[2015-16]Status: DisposedITAT Chennai24 Feb 2025AY 2015-16

For Appellant: Shri Clement Ramesh Kumar (CIT) -Ld. DRFor Respondent: Shri M.V. Swaroop (Advocate) - Ld. AR

Section 132Section 143

Prakash Praveen Kumar, Bangalore vs. Income Tax Officer, Ward - 2(2)(3), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 636/BANG/2024[2018-19]Status: DisposedITAT Bangalore24 Feb 2025AY 2018-19

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

For Appellant: Sri Balram R Rao, A.RFor Respondent: Shri V. Parithivel, D.R

Section 142(1)Section 143(2)Section 143(3)Section 194CSection 250Section 44ASection 69

presumptions treated the assessee as bogus seller and had added once in the head of “Bank credits” of Rs.60,56,515/- and another as unexplained investment of Rs.20,09,195/- for issuing fake invoice. Further, the ld. A.R. of the assessee submitted that since the assessee has declared its income ... same fictitious bills without actual movement of goods or services and accordingly added the same as Prakash Praveen Kumar, Bangalore Page 5 of 7 unexplained investment u/s 69 of the Act. However, on going through the proceedings before Asst. Commissioner of Commercial Taxes (Enforcement) – 11 South zone, Bangalore placed

Income Tax Officer, International Taxation, Ward-1(2), Bengaluru vs. Ms. Stany Basil Mathias, Karnataka

In the result, appeal filed by the revenue is dismissed

ITA 1694/BANG/2024[2019-20]Status: DisposedITAT Bangalore24 Feb 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Shri V. Parithivel, D.R

Section 142(1)Section 144Section 144C(1)Section 147Section 148ASection 156Section 250Section 69

issued a notice of demand under Section 156 of the Act for Rs.5,42,89,053/-. Sl No Details Of Investment Amount (Rs) 1 Unexplained Investments u/s 69 3,32,96,002/- 4,242/- 2 Income from Other Source Short term Capital Gain on sale of 3 9,750/- Securities

Harsha, Jiwana Baghpat vs. Income Tax Officer Ward 1(5) Baraut, Baraut

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

ITA 3527/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Feb 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalincome Tax Officer, Harsha, Ward-1(5), Jiwana Baghpat-250611, Vs. Baraut. Uttar Pradesh. Pan-Adlph3085L (Appellant) (Respondent) Assessee By Shri R.K. Gaur, Ca Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 24/02/2025 Date Of Pronouncement 24/02/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) Vide Order U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”) Dated 01/11/2023 For The Asst. Year 2012-13. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & During This Year Had Purchased An Agricultural Land Measuring 8.8200 Hectare In Auction Jointly With Five Other Persons At A Total Sale Consideration Of Rs.1,50,82,200/-. Beside This A Sum Of Rs. Harsha Vs. Ito 7,55,000/- Was Paid Towards Stamp Duty Making Total Cost Of Land Was At Rs. 1,65,92,000/-. As The Assessee Has Not Filed Any Return Of Income, The Reassessment Proceedings Were Initiated By Issue Of Notice U/S 148 On 29/03/2019. The Assessee Has Not Attended The Reassessment Proceedings & The Finally The Reassessment Order Was Passed U/S 144/147 Of The Act On 7/12/2019 Wherein The Ao Had Made The Addition Of Rs. 27,65,333/- Being His Share In Investment In Acquisition Of The Property From Undisclosed Sources.

Section 144Section 148Section 250

subject, the learned officer was not justified in treating the invested amount in the property amounting to Rs.27,65,333/- as unexplained investment. The Ld. Officer ignored the fact that the assessee was a part of the AOP which took the auction of the land with other five people also

DCIT, Central Circle- 28, New Delhi vs. Hazoorilal and Sons Jewellers Private Limited, New Delhi

Appeal of the assessee is allowed

ITA 3497/DEL/2023[2017-18]Status: DisposedITAT Delhi24 Feb 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish Agarwal (Accountant Member)

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 69Section 69A

before the AO. However, the submissions made by the assessee were not accepted and AO is treated the entire contribution of Rs.3.50 crores as unexplained investment of the assessee u/s 69A of the Act. 3. Against the said order, the assessee is in appeal before the Tribunal wherein the assessee ... submitted in Assessment/ Appellate Proceedings: - Lower Authorities have grossly erred in making/confirming addition of Rs.3,50,00,000/- under section 69 on account of unexplained investments without considering the facts of the case, submissions made by Assessee and documents produced by Assessee in assessment and appellate proceedings, therefore addition made

Sanjay Sahu, Bhopal vs. The Th4E ITO 2(1), Byhopal

ITA 172/IND/2023[2010-11]Status: DisposedITAT Indore21 Feb 2025AY 2010-11

Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyaniassessment Year:2010-11 Sanjay Sahu, Ito 2(1), H.No.98-A Sector, Bhopal बनाम/ Kasturba Nagar, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Apyps1707D Assessee By Shri Shashank Sharma, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 12.02.2025 Date Of Pronouncement 21.02.2025

Section 143(3)Section 253(5)Section 68Section 69Section 80C

erred in confirming the action of Assessing Officer in making addition of Rs.7,60,800/- u/s 69 of the Act on account of unexplained investment which was not pertained to the appellant and is therefore unjust, illogical and arbitrary and deserves to be quashed. 4. That on the facts ... partly complied. Ultimately, the AO passed assessment-order after making three additions/ disallowances, namely (i) addition of Rs. 7,60,800/- on account of unexplained investment in a property situated at Gram – Bawadia Laka, Patwari Halka No. 42, Tahsil Hujur, Bhopal; (ii) addition of Rs. 4,46,000/- on account

Amish Purshottamdas Patel, Petlad vs. ITO Petlad, Petlad

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

ITA 578/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad21 Feb 2025AY 2013-14

Bench: Shri T.R. Senthil Kumar

For Appellant: NoneFor Respondent: Shri Rignesh Das, Sr.DR

Section 143(3)

determining an assessed income of Rs.65,21,330/-. During the course of assessment proceedings, the Assessing Officer (AO) made two primary additions namely - i. Unexplained Investment in Land - Rs.55,48,300/-. ii. Undisclosed Sale of Property - Rs.5,59,565/- as Short-Term Capital Gain (STCG). 3. The assessee preferred

Harsal Jagannath Gavate, Dhule vs. The Income Tax Officer, Ward-1, Dhule

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

ITA 1622/PUN/2024[2013-14]Status: DisposedITAT Pune21 Feb 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1622/Pun/2024 िनधा"रण वष" / Assessment Year: 2013-14 Harsal Jagannath Gavate, V The Income Tax Officer, At Post Khede Dhule, S Ward-1, Dhule. Dist. Dhule – 424302. Pan: Bdjpg2600P Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte –Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 17/02/2025 Date Of Pronouncement 21/02/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2013-14 Dated 14.06.2024 Passed U/Sec.250 Of

Section 147Section 148Section 250Section 69A

treating the entire credits made to the account held with the co-operative society as unexplained investments. 6. On the basis of the facts and circumstances of the case, the Commissioner of Income-tax (Appeal) is not justified in confirming ITA No.1622/PUN/2024 [A] the addition of Rs.1

Guni Govindachetty Ashokkumar, Krishnagiri vs. ITO, Ward-1, Krishnagiri

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

ITA 3144/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Feb 2025AY 2012-13

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.3144/Chny/2024 िनधा"रण वष" /Assessment Year: 2012-13 Guni Govindachetty Ashokkumar, The Income Tax Officer, 3/149/4, Emakalnatham Vill & Po Vs. Ward-1, Bargur, Krishnagiri – 635104. Krishnagiri. [Pan: Aelpa 3144A]

For Appellant: Mrs. Mathangi, AdvocateFor Respondent: Ms. Gauthami Manivasagam, JCIT

Section 144Section 249(2)(b)Section 249(3)Section 69

below. We note that the assessment order was passed by the A.O on 28.12.2019 by making addition of :- 4 -: Rs.1,98,17,298/- as unexplained investment u/s. 69 of the Act without participation of the assessee u/s. 144 r.w.s 147 of the Act. Further, the Ld. CIT(A) also

Deputy Commissioner of Income Tax, Chennai vs. Periampillai Nadar Thangavelu Soundarpandian, Madurai

In the result, appeal filed by the Revenue is dismissed

ITA 2752/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Feb 2025AY 2017-18

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 2752/Chny/2024 िनधा$रण वष$ / Assessment Year: 2017-18 Periampillai Nadar Thangavelu Deputy Commissioner Of Income Soundarapandian, Tax, Vs. 1/1, P.P. Chavadi Theni Road, Central Circle-2(3) Madurai – 625 016. Chennai. [Pan: Adbps-2536-H]

For Appellant: Mr. R. Anitha, Addl. CITFor Respondent: Mr. R. Venkataraman, CA

Section 132Section 132(4)Section 147Section 153ASection 153CSection 69

facts of the case. 5. The Ld. CIT(A) erred in deleting the addition of Rs. 1 crore of loan advanced u/s 69 as unexplained investment when the assessee himself in his sworn statement recorded u/s 132(4) during the course of search has acceded to the same and also ... Shri S.Seetharaman. However, the AO rejected the explanation of the assessee and treated the sum of Rs.1,00,00,000/- as unexplained investment u/s.69 of the Act in the hands of the assessee by passing an order u/s.147 of the Act dated 24.03.2022. The AO made an addition only

Sri. D. K Shivakumar, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

ITA 1064/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Feb 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan Kassessment Year : 2018-19

For Appellant: S/ShriFor Respondent: Shri.Y. V. Raviraj, Sr. Standing Counsel

Section 132(4)Section 143(2)Section 250Section 292CSection 69ASection 69B

Safdarjang Enclave Rs. 6,61,26,000/- (4) Unaccounted money seized from residence of Mr. Anjaneya Rs. 15,00,000/- (5) Unexplained investment towards Late Mrs. Vishalakshi Devi Property Rs. 4,00,00,000/- (6) Unexplained investment made by Mr. Chandrashekhar Sukhapuri on behalf of the Assessee ... approved by the Supreme Court, when the SLP filed by the Revenue was dismissed. 5. ADDITION OF RS. 4,00,00,000/- u/s 69 UNEXPLAINED INVESTMENT OF THE ACT. Mr Sachin Narayan, who has owned up the cash payment made to Vishalakshi devi , is not a man of straw

Asha Vijaykumar Mittal, Mumbai vs. ITO, Ward 41(3)(1), Mumbai

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

ITA 94/MUM/2025[2009-10]Status: DisposedITAT Mumbai21 Feb 2025AY 2009-10

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI. OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri. Shirish ShahFor Respondent: Shri. Kiran Unavekar SR. DR

Section 131Section 142(1)Section 144Section 148Section 250

erred in facts and circumstances of the case and in law in making an addition of Rs.8,25,000/- on account of unexplained investment to the income of the appellant. 6. The appellant reserves the right to add, alter, amend, delete or modify any ground or grounds of appeal ... dated 18.02.2021, where the ld. AO determined the total income at Rs. 9,98,950/- after making addition of Rs. 8,25,000/- as unexplained investment. 3. Aggrieved the assessee was in appeal before the first appellate authority, challenging the assessment order. 4. The ld. CIT(A) vide order dated

Aarti Sudarshan Soni, Mumbai vs. Income Tax Officer-30(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3233/MUM/2024[2014-15]Status: DisposedITAT Mumbai21 Feb 2025AY 2014-15

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Dr. K. Shivram, Sr. Adv. & NilamFor Respondent: Shri Asif Karmali, Sr. DR

Section 132Section 69

assessee raised the following ground of appeal:- 2 ITA No.3233/Mum/2024-Aarti Sudarshan Soni “I. Addition of Rs. 33,00,000/-made u/s 69 as an unexplained investment 1. The learned National Faceless Appeal Centre (NFAC) erred in confirming the addition of Rs.33,00,000/- as an unexplained investment u/s.69 ... Invt.), Unit 2(2) without appreciating that the appellant has not paid any consideration in cash hence the addition of Rs.33,00,000 as unexplained investment may be directed to be deleted. 2. The learned National Faceless Appeal Centre (NFAC) failed to appreciate that there is no difference in consideration

M/S Orthopaedics and Trauma Center, Jhalawar vs. DCIT, Central Circle, Kota

25. In view of the above discussion, reasons and findings, this appeal deserves to be allowed

ITA 1444/JPR/2024[2019-20]Status: DisposedITAT Jaipur20 Feb 2025AY 2019-20

Bench: the ld. CIT(A), assessment order dated 2-06-2021 was under challenge. Vide said assessment order, the AO computed total income of the assessee at 1,02,55,230/- by observing in the manner as:-

For Appellant: Shri P.C. Parwal, CAFor Respondent: Sh. Manoj Kumar, JCIT-DR

Section 115BSection 139Section 143(2)Section 143(3)Section 156Section 234BSection 244ASection 250Section 271ASection 274

excess cash of Rs. 8,28,900/- and excess stock of Rs. 4,68,290/- offered during the survey proceedings are considered as unexplained investment, unexplained money and amount of investments, etc., not fully disclosed in books of account as per provision of section

Narender Kumar, 251, 13 Co Garg Kiryana Store, Main Bazar Radaur, Yamunanagar, Haryana vs. Income Tax Officer, Ward-5, Yamunanagar, Haryana

In the result, appeal is partly allowed

ITA 812/CHANDI/2024[2011-2012]Status: DisposedITAT Chandigarh20 Feb 2025AY 2011-2012

Bench: Shri Rajpal Yadav

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

Section 144Section 17Section 49

that impugned addition is not sustainable. 6. As far as re-opening of assessment is concerned, since revenue was possessing specific information about alleged unexplained investment, therefore, AO has rightly formed a prima facie opinion about escapement of income but on merit, assessee has explained the source of such investment

Smt. Teena Garg, Chandigarh vs. PCIT, Panchkula

In the result, appeal of the assessee is allowed

ITA 466/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh20 Feb 2025AY 2015-16

For Respondent: Shri Sudhir Sehgal, Advocate

Section 142(1)Section 143(2)Section 147Section 148Section 253Section 263

PCIT vs. SHREEJI PRINTS (P.) LTD.* as reported in [2021] 130 TAXAAANN.COM 294 (SC) Section69, read with section263, of the Income-tax Act, 1961 Unexplained investments (Unsecured loans) - Assessment year 2013- 14 - Assessee-company had received unsecured loans from two different companies - Commissioner noting that said loans were shown