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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

Assistant Commissioner of Income Tax, Central Circle-1(2), Nagpur vs. Shri Madhusudan M. Mude, Nagpur

In the result, appeal filed by the assessee is dismissed

ITA 137/NAG/2021[2016-17]Status: DisposedITAT Nagpur29 Jan 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 132Section 132(4)

case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 18,00,000 made by AO on account of unexplained investment in purchase of property. 2. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting ... case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 7,15,518/ made by AO on account of unexplained investment in jewellery. 4. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in appreciating the fact

Madhusudan Marotrao Mude, Nagpur vs. Assistant Commissioner of Income Tax, Central Circle 1(2), Nagpur

In the result, appeal filed by the assessee is dismissed

ITA 132/NAG/2021[2014-15]Status: DisposedITAT Nagpur29 Jan 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Sandipkumar Salunke
Section 132Section 132(4)

case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 18,00,000 made by AO on account of unexplained investment in purchase of property. 2. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting ... case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 7,15,518/ made by AO on account of unexplained investment in jewellery. 4. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in appreciating the fact

Deputy Commissioner of Income Tax (Central Circle)-1(4), Ahmedabad vs. Deep Infraprojects LLP, Ahmedabad

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

ITA 1561/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad29 Jan 2025AY 2021-22

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1561/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2021-22) Deputy Commissioner Of Vs. Deep Infraprojects Llp 10Th Floorhouse, Income Tax Central Circle-1(4), Nr. Ambawadi Circle, Ahmedabad Ambawadi, Ahmedabad- 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfd3530J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Vartik Choksi, Shri Dhrunal Bhatt & Shri Gulab Thakor, A.Rs. ""यथ" क" ओर से/Respondent By : Shri Arvind Kumar, Cit. Dr 22/01/2025 Date Of Hearing Date Of Pronouncement 29/01/2025 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals)- 11, Ahmedabad (In Short ‘The Cit(A)’), Dated 05.07.2024 For The Assessment Year 2021-22. 2. The Brief Facts Of The Case Are That The Assessee Had Purchased A Land Situated At Ambli Road, Ahmedabad During The Year For A Consideration Of Rs.75 Crore, As Per The Executed Sale Deed. In The Course Of Search Conducted At The Residential Premises Of One Shri Divyang Vyas, Certain Documents Were Found, As Per Which It Transpired That Certain On-Money Was Paid In The Purchase Transaction Of This Land. In The Course Of

For Appellant: Shri Vartik Choksi, Shri DhrunalFor Respondent: Shri Arvind Kumar, CIT. DR
Section 69B

made an addition of difference amount of Rs.25.78 Crores u/s.69B of the Income Tax Act, 1961 (in short ‘the Act’) on account of unexplained investment in the property. 3. Aggrieved with the order of the AO, the assessee had filed an appeal before the Ld. CIT(A), which was decided ... erred in deleting the addition of Rs.25,78,00,000/- as per provision of Section 69B of the Income Tax Act on account of unexplained investment for purchase of land without appreciating the seized documents and report of DVO wherein DVO arrived at the value of land after considering

Shekhar Bajirao Bhilare, Mahabaleshwar vs. I.T.O Ward-4, Satara

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

ITA 158/PUN/2025[2017-18]Status: DisposedITAT Pune29 Jan 2025AY 2017-18

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2017-18

For Appellant: Smt. Deepa KhareFor Respondent: Shri Arvind Desai, Addl CIT-DR
Section 142(1)Section 144Section 147Section 148Section 69Section 69A

which the Assessing Officer completed the assessment u/s 144 of the Act by bringing to tax an amount of Rs.2,47,90,341/- as unexplained investment u/s 69 of the Act. 4. In appeal, the Ld. CIT(A) / NFAC sustained the addition made by the Assessing Officer. 5. Aggrieved with

Buildcube Constructions Pvt Ltd, Mumbai vs. ITO, Ward 1(1), Thane

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

ITA 5015/MUM/2024[2011-12]Status: DisposedITAT Mumbai29 Jan 2025AY 2011-12

Bench: Shri Saktijit Dey & Shri B.R. Baskaranassessment Year : 2011-12 Buildcube Constructions Pvt. Income Taxofficer, Ltd., Ward-1(1), Office No. G-01, Vs. B-Wing, 6Th Floor, Ground Floor,Mirani Nagar, Ahsar It Park Road No.16Z, Kopri Colony Road, Wagle Ind. Estate, Near Union Bank Of India, Thane, Thane (E), Maharashtra Maharashtra Pan : Aaccb3253H (Appellant) (Respondent) For Assessee : Shri Subodh Ratnaparkhi For Revenue : Shri Kailash C. Kanojiya, Cit-Dr Date Of Hearing : 27-01-2025 Date Of Pronouncement : 29-01-2025

For Appellant: Shri Subodh RatnaparkhiFor Respondent: Shri Kailash C. Kanojiya, CIT-DR
Section 143(1)Section 143(3)Section 147Section 2(40)

Rs.7,83,78,790/-. Thus, the stock in progress is inflated by an amount of Rs.1,76,28,790/- (78378790-62650000), which is unexplained investment of the assessee therefore required to be brought to tax. 4. In this case a return of income was filed for the year under consideration ... shown as stock in progress in the books of account. He did not make any addition as mentioned in the reasons for reopening towards unexplained investment. However, the AO made addition of Rs.11.16 crores, being the difference between the purchase consideration and the stamp duty value. Presumably

ACIT, Circle - 1, Belagavi vs. Rohit Parasharam Patil, Belagavi

Accordingly. The grounds of appeal stands accordingly partly allowed

ITA 71/PAN/2022[2017-18]Status: DisposedITAT Panaji28 Jan 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 071/Pan/2022 Assessment Year : 2017-18

For Appellant: Mr Omkar Godbole [‘Ld. AR’]For Respondent: Mr Narendra Reddy [‘Ld. DR’]
Section 115BSection 143(1)Section 143(2)Section 144Section 250Section 251Section 253(2)Section 69

whereby the entire amount of cash/SBN of ₹1,99,11,000/- deposited by the assessee were added to total income as his unexplained investment and assessed the same to tax u/s 115BBE of the Act. Aggrieved by the aforestated addition the assessee filed first appeal which came to be allowed ... show cause notice u/s 144 of the Act completed the assessment to best of his judgement by treating entire cash deposits as the ‘unexplained investment’ of the respondent assessee u/s 69 of the Act and brought same to tax u/s 115BBE of the Act. 4 Though the matter travelled

Rakesh Kumar Sharma, Patna vs. Income Tax Officer, Income Tax Department

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

ITA 451/PAT/2024[2015-16]Status: DisposedITAT Patna28 Jan 2025AY 2015-16

Bench: Sri Sanjay Garg & Shri Sanjay Awasthi

Section 250Section 69

payment of advance tax. 5. We note that in this case, the impugned addition has been made by the Assessing Officer on account of unexplained investment u/s. 69 of the Act. However, the assessee has disputed the aforesaid addition made by the Assessing Officer which was subject matter of adjudication

Shrenikkumar Natvarlal Vora, New Pashupati Market vs. Income Tax Officer, Ward 2(2)(4), Aayakar Bhavan, Surat

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

ITA 529/SRT/2024[2012-13]Status: DisposedITAT Surat28 Jan 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth(Physical Hearing) Shrenikkumar Natvarlal Vora, I.T.O., 1012 New Pashupati Market, Ring Ward 2(2)(4), Vs. Road, Surat-395002 (Gujarat) Aayakar Bhavan, Pan No. Aalpv 6626 N Surat. Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 250Section 254(1)Section 69

r.w.s. 147 of the Income Tax Act, 1961 (in short, the Act), addition under Section 69 of the Act on account of unexplained investment of Rs. 11,27,715/- and violation of principles of natural justice by not allowing reasonable and sufficient opportunity by the ld. CIT(A). 2. Rival ... passed the order in absence of any submission of assessee and confirmed the addition made by the Assessing Officer on account of unexplained investment. The ld. AR of the assessee submits that the assessee has good case on merit and is likely to succeed if one opportunity is allowed

Nuruddin Alihusain Suratwala, Amatullah Manzil vs. ITO Ward 4(4) Nagpur, Bsnl Rttc Building

In the result, appeal of the assessee is allowed

ITA 459/NAG/2024[2018-19]Status: DisposedITAT Nagpur28 Jan 2025AY 2018-19

Bench: Shri V. Durga Rao

For Appellant: MS. Alfiya Rozie, C.AFor Respondent: Shri Abhay Y. Marathe, Sr. DR
Section 143(2)Section 144Section 147Section 250(6)Section 69

Assessing Officer passed ex-parte assessment order u/sec.144 r.w.s.147 and 144B of the Act by making addition of Rs.17,08,280/- on account of unexplained investment u/sec.69 of the Act; Rs.10,78,000/- on account of income from other sources u/se.56(2)(x) of the Act and determined the total

Sh. Dheeraj Singh Sisodiya, Kota vs. DCIT, Central Circle, Kota

In the result the ground no

ITA 936/JPR/2024[2018-19]Status: DisposedITAT Jaipur28 Jan 2025AY 2018-19

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

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 153ASection 69

erred on facts & in law in confirming the addition of Rs. 5,59,890/- u/s 69 of the Act on account of alleged unexplained investment in purchase of agriculture land by not accepting the explanation of assessee that the source of same is out of agriculture income ... added to his total income treating same as unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here

Sh. Dheeraj Singh Sisodiya, Kota vs. DCIT, Central Circle, Kota

In the result the ground no

ITA 935/JPR/2024[2017-18]Status: DisposedITAT Jaipur28 Jan 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 153ASection 69

erred on facts & in law in confirming the addition of Rs. 5,59,890/- u/s 69 of the Act on account of alleged unexplained investment in purchase of agriculture land by not accepting the explanation of assessee that the source of same is out of agriculture income ... added to his total income treating same as unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here

Sh. Dheeraj Singh Sisodiya, Kota vs. DCIT, Central Circle, Kota

In the result the ground no

ITA 934/JPR/2024[2016-17]Status: DisposedITAT Jaipur28 Jan 2025AY 2016-17

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

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 153ASection 69

erred on facts & in law in confirming the addition of Rs. 5,59,890/- u/s 69 of the Act on account of alleged unexplained investment in purchase of agriculture land by not accepting the explanation of assessee that the source of same is out of agriculture income ... added to his total income treating same as unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here

Sh. Dheeraj Singh Sisodiya, Kota vs. DCIT, Central Circle, Kota

In the result the ground no

ITA 933/JPR/2024[2015-16]Status: DisposedITAT Jaipur28 Jan 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 153ASection 69

erred on facts & in law in confirming the addition of Rs. 5,59,890/- u/s 69 of the Act on account of alleged unexplained investment in purchase of agriculture land by not accepting the explanation of assessee that the source of same is out of agriculture income ... added to his total income treating same as unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here

Sh. Dheeraj Singh Sisodiya, Kota vs. DCIT, Central Circle, Kota

In the result the ground no

ITA 932/JPR/2024[2014-15]Status: DisposedITAT Jaipur28 Jan 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 153ASection 69

erred on facts & in law in confirming the addition of Rs. 5,59,890/- u/s 69 of the Act on account of alleged unexplained investment in purchase of agriculture land by not accepting the explanation of assessee that the source of same is out of agriculture income ... added to his total income treating same as unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here

Sh. Dheeraj Singh Sisodiya, Kota vs. DCIT, Central Circle, Kota

In the result the ground no

ITA 931/JPR/2024[2012-13]Status: DisposedITAT Jaipur28 Jan 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आयकर अपील सं. / ITA Nos.931 to 936/JP/2024 निर्धारण वर्ष / Assessment Years : 2012-13 & 2014-15 to 2018-19 Dheeraj Singh Sisodiya 005, (Nayagaun) Ram Ganmandi, Kota बनाम DCIT, Vill. Beedmandi Vs. Central Circle, Kota स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: APAPS 6392 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Sh. P. C. Parwal, CA राजस्व की ओर से / Revenue by : Mrs. Alka Gautam,

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 132Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 153ASection 69

erred on facts & in law in confirming the addition of Rs. 5,59,890/- u/s 69 of the Act on account of alleged unexplained investment in purchase of agriculture land by not accepting the explanation of assessee that the source of same is out of agriculture income ... added to his total income treating same as unexplained investment u/s 69 of the Act. 6. Aggrieved from the order of Assessing Officer, assessee preferred an appeal before the ld. CIT(A). Apropos to the grounds so raised the relevant finding of the ld. CIT(A) is reiterated here

Nitesh Agarwal, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

Appeal is partly allowed

ITA 1214/JPR/2024[2012-13]Status: DisposedITAT Jaipur28 Jan 2025AY 2012-13

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri S. L. Poddar, Adv. &For Respondent: Shri Arvind Kumar, CIT-DR
Section 143(2)Section 143(3)Section 144Section 145(3)Section 68Section 69B

erred in confirming the addition of Rs. 1,00,00,000/- u/s 69B of the Income Tax Act, 1961 on account alleged unexplained investment in land. 5. In the facts and circumstances of the case the learned CIT(A) has erred in confirming the addition ... balance sheet of the assessee. (iii) Addition of Rs. 1,00,00,000/- u/s 69B of the Income Tax Act, 1961 on account alleged unexplained investment in land. (iv) Addition of Rs. 21,91,651/- applying NP rate at 9.33%. (Copy of assessment order dated 30.03.2015 is available on paper

Olive Tree Trading Pvt Ltd, Pune vs. ITO, Circle 2, Pune

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

ITA 899/PUN/2024[2018-19]Status: DisposedITAT Pune28 Jan 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Narendra JoshiFor Respondent: Shri Amol Khairnar
Section 115BSection 143(1)Section 143(2)Section 144Section 147Section 40Section 69C

order of Ld AO considering the advertisement and brand promotional expenses capitalised under head intangible asset amounting to Rs. 5,26,56,277 as unexplained investment under section 69C of the IT Act and thereby erred in disallowing depreciation amounting to Rs. 66,39,484/- 2 ITA No.899/PUN/2024 ... vide his order dated 08.03.2021 by making the following additions :-(i) Rs.5,26,56,277/- is added u/s 69C of the Act as unexplained investment for purchasing of Intangible Assets during the AY 2018-19 relevant to the FY 2017-18 and brought to tax u/s 115BBE

Income Tax Officer, Dhule vs. Dhule Zilha Parishad Karmachari Sahakari Patpedhi Maryadit Dhule, Dhule

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

ITA 769/PUN/2024[2020-21]Status: DisposedITAT Pune28 Jan 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sanket M. JoshiFor Respondent: Shri Amol Khairnar
Section 143(1)(a)Section 143(2)Section 144Section 68Section 80P(2)(a)

that amount which was credited in books of account of the assessee in the preceding year cannot be treated as unexplained cash credit or unexplained investment under s. 68/69 in the relevant assessment year. The relevant part of the High Court’s order is reproduced as under:- “Held : There ... clear finding and about which there is no dispute that the amount added in the income of the assessee as unexplained investment or cash 4 ITA No.769/PUN/2024, AY 2020-21 credit in the asst. yr. 1993-94 was the same amount which was credited in the books of account

Bal Reddy Kandunuri, Adilabad vs. ACIT, Central Circle-2(4), Hyderabad

In the result, appeal of the assessee is allowed

ITA 1203/HYD/2024[2020-21]Status: DisposedITAT Hyderabad28 Jan 2025AY 2020-21

Bench: Shri G. Manjunatha & Shri K. Narasimha Chary

For Appellant: Shri A.V. Raghuram, ARFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 115BSection 131Section 132ASection 153ASection 69A

which additional income offered towards excess stock to be assessed, whether it is under the head profits and gains of business or profession or unexplained investment as per section 69B of the Act. 11. The provisions of section 69B of the Act deals with, where in any financial year ... accepted explanation of the assessee and assessed the income under the head profits and gains of business or profession, but not under the head unexplained investment u/s. 69B of the Act. This is because, excess stock found during the course of survey does not have any independent identity

Bal Reddy Kandunuri, Hyderabad vs. ACIT, Central Circle-2(4), Hyderabad

ITA 1202/HYD/2024[2019-20]Status: DisposedITAT Hyderabad28 Jan 2025AY 2019-20

Bench: Shri G. Manjunatha & Shri K. Narasimha Chary

For Appellant: Shri A.V. Raghuram, ARFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 115BSection 131Section 132ASection 153ASection 69A

which additional income offered towards excess stock to be assessed, whether it is under the head profits and gains of business or profession or unexplained investment as per section 69B of the Act. 11. The provisions of section 69B of the Act deals with, where in any financial year ... accepted explanation of the assessee and assessed the income under the head profits and gains of business or profession, but not under the head unexplained investment u/s.69B of the Act. This is because, excess stock found during the course of survey does not have any independent identity as the asset