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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

Ajay Thakur, Dehradun vs. ITO, Ward-1(1)(1)1, Dehradun

Appeal is partly allowed

ITA 60/DDN/2023[2017-18]Status: DisposedITAT Dehradun27 Jan 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra(Through Video Conferencing) Assessment Year: 2017-18 Vs. Income Tax Officer, Sh. Ajay Thakur, S/O- Sh. Surendra Singh, 31-Purbiya Ward-1(1)(1)1, Lines, Hospital Road, Dehradun Vikas Nagar, Dehradun Pan: Afkpt5059D (Appellant) (Respondent) Assessee By Sh. Rajiv Sahni, Ca Department By Sh. A.S. Rana, Sr. Dr Date Of Hearing 10.01.2025 Date Of Pronouncement 27.01.2025 Order

Section 115BSection 147Section 2(14)Section 56(2)(vii)Section 69

Learned counsel submits that the assessee’s second substantive issue canvassed in the instant appeal challenges both the lower authorities’ action making section 69 unexplained investment addition of Rs.12 lakhs which has been held liable to be assessed under section 115BBE of the Act. He seeks to buttress the point

Jugal Chandra Saikia, Guwahati vs. Income Tax Officer, Ward-1(3), Guwahati

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

ITA 259/GTY/2018[1993-94]Status: DisposedITAT Guwahati27 Jan 2025AY 1993-94

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 143Section 250Section 254

Howly ICDP (1/13th of 60% of 1, 21, 35, 879/-) 560117 Nagaon Treasury (1/5th of 60% of 21, 00, 177/-) 252021 1747899 Unexplained investment in residential building 760455 Total disputed additions to income: 2508354 I.T.A. Nos.: 258 & 259/GTY/2018 Assessment Years: 1992-93 & 1993-94 Jugal Chandra Saikia. 1.1 In appeal

Jugal Chandra Saikia, Guwahati vs. Income Tax Officer, Ward-1(3), Guwahati

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

ITA 258/GTY/2018[1992-93]Status: DisposedITAT Guwahati27 Jan 2025AY 1992-93

Bench: Sri Manomohan Das & Sri Rakesh Mishra

Section 143Section 250Section 254

Howly ICDP (1/13th of 60% of 1, 21, 35, 879/-) 560117 Nagaon Treasury (1/5th of 60% of 21, 00, 177/-) 252021 1747899 Unexplained investment in residential building 760455 Total disputed additions to income: 2508354 I.T.A. Nos.: 258 & 259/GTY/2018 Assessment Years: 1992-93 & 1993-94 Jugal Chandra Saikia. 1.1 In appeal

Empire Builders, Ernakulam vs. Deputy Commissioner of Income Tax, Ernakulam

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

ITA 166/COCH/2024[2007-08]Status: DisposedITAT Cochin27 Jan 2025AY 2007-08

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2007-08

For Appellant: NoneFor Respondent: Smt. Leena Lal, Snr. AR
Section 142ASection 28Section 69C

which was disputed by the assessee before the Page 3 of 4 Ld.CIT(A). The assessee contended that the estimated gross profit as unexplained investment u/s. 69C of the Act is not correct since the value estimated by the departmental valuer had not considered the certain other major expenditures

Suresh Kumar Saini, Jaipur vs. NFAC, Delhi

16. For the foregoing discussion and findings, this appeal deserves to be allowed

ITA 1256/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Jan 2025AY 2016-17

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

For Appellant: Sh. Neeraj Gupta, C.AFor Respondent: Sh. Anup Singh, Addl.CIT
Section 143(3)Section 148Section 234ASection 250Section 271(1)Section 271(1)(c)Section 69

r.w.s. 147 of the Act. Thereby the Assessing Officer computed total income of the assessee as under:- In Rs. Addition u/s 69 as unexplained investment 47,77,300 Agriculture income assessee as income from other 5,48,550 sources Total income 53,25,850 Rounded ... Ground No. 2 raised there, the assessee challenged addition of Rs. 47,77,300/- i.e. u/s 69 of the Act as regards unexplained investment. Having considered the material made available in the appeal, Learned CIT(A) was of the view that source of cash deposits to the tune

Prem Chand Gupta, Alwar vs. ITO Ward 2(3), Alwar

16. For the foregoing discussion and findings, this appeal deserves to be allowed

ITA 1251/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Jan 2025AY 2012-13

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

For Appellant: Sh. Neeraj Gupta, C.AFor Respondent: Sh. Anup Singh, Addl.CIT
Section 143(3)Section 148Section 234ASection 250Section 271(1)Section 271(1)(c)Section 69

r.w.s. 147 of the Act. Thereby the Assessing Officer computed total income of the assessee as under:- In Rs. Addition u/s 69 as unexplained investment 47,77,300 Agriculture income assessee as income from other 5,48,550 sources Total income 53,25,850 Rounded ... Ground No. 2 raised there, the assessee challenged addition of Rs. 47,77,300/- i.e. u/s 69 of the Act as regards unexplained investment. Having considered the material made available in the appeal, Learned CIT(A) was of the view that source of cash deposits to the tune

Arti Surana, Howrah vs. I.T.O., Ward - 47(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1405/KOL/2024[2018-2019]Status: DisposedITAT Kolkata27 Jan 2025AY 2018-2019

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.1405/Kol/2024 Assessment Year: 2018-19 Arti Surana………………………………..……………………….....Appellant Flat 5Cd, Block Iv, 5Th Floor, Vivek Vihar, Phase V, 493/C/A, G. T Road (South), Howrah-711101. [Pan: Akcpp7261L] Vs. Ito, Ward-47(1), Kolkata……….……….…............................…..…..... Respondent Appearances By: Shri Rajkumar Agarwal, Ar, Appeared On Behalf Of The Appellant. Shri Ashutosh Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 15, 2025 Date Of Pronouncing The Order : January 27, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 29.04.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Her Return Of Income For The Assessment Year 2018-19 By Declaring Total Income Of Rs.3,23,590/-. The Assessing Officer Found The Assessee Has Showed Income Under The Heads Of Short-Term Capital Gain & Other Sources. The Assessee Claimed Exemption Under The Head Of Short-Term Capital Gain From Transaction On Which Securities Transaction Tax Is Paid. However, During The Assessment Proceedings, The Department Received Information Which Indicated That The Assessee Had Traded In Shares Of Amm Ltd. & Eml Scrip Code (538653) To The

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 250Section 250(6)Section 69Section 69A

total income of the assessee. Additionally, the Assessing Officer treated the investment of Rs.35,90,829/- (used in equity shares) as unexplained investment u/s 69 of the Act as the assessee failed to provide the explanation regarding the same. Moreover, the Assessing Officer added an amount of Rs.3

Sandeep Agarwal, Mumbai vs. DCIT-6(3), Mumbai

ITA 6213/MUM/2024[2006-07]Status: DisposedITAT Mumbai27 Jan 2025AY 2006-07

Bench: Shri Amarjit Singh & Shri Anikesh Banerjeesandeep Agarwal, Vs Deputy Commissioner Of Income 36/40, Mahalaxmi Bridge Tax 6(3), Mumbai, Arcade, Mahalaxmi, Mumbai- Ayakar Bhavan, 400 034 M.K. Road, Mumbai-400 020 Pan: Aacpa5201H Appellant Respondent

For Appellant: Shri Haridas BhatFor Respondent: Shri Asif Karmali (SR DR)
Section 133(6)Section 143(3)Section 147Section 148Section 250Section 69

case, and in Law, CIT(A), NFAC erred in confirming the addition of Rs. 5,32,900/- u/s 69 of the Act as Unexplained Investment towards the alleged bogus purchase of shares as undisclosed income based on surmises and conjectures, without any evidence. b. The CIT(A) Failed to appreciate ... receipts are made from bank Accounts. c. Your appellant prays that the addition of Rs. 5,32,900/ u/s 69 of the Act as Unexplained Investment towards the alleged bogus purchase of shares as undisclosed income may please be deleted.” 3. The brief fact of the case is that

Kshama Sanjay Tripathi, Ahmedabad vs. The ITO, Ward-4(2)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 450/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2010-11

Bench: Dr. Brr Kumar & Ms Suchitra Kamblei.Ta. No.450/Ahd/2020 (Assessment Year: 2010-11) Kshama Sanjay Tripathi, Vs. The Income Tax Officer, 76, Super Bunglow, Ward-4(2)(2), Science City, Ahmedabad. Sola Road, Ahmedabad-380060. [Pan No.Afypt1577L] (Appellant) .. (Respondent) Appellant By : Shri Mehul K Patel, Ar Respondent By: Shri Rignesh Das, Sr. Dr 13.01.2025 Date Of Hearing Date Of Pronouncement 24.01.2025 O R D E R

For Appellant: Shri Mehul K Patel, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 144Section 148

That, on facts, and in law, the learned CIT (A) has grievously erred in confirming the addition of Rs. 40, 00,000/- made as unexplained investment in purchase of property. Asst.Year –2010-11 - 2– 2. That on facts and in law, the learned CIT (A) has grievously erred in enhancing

Nimesh Umakant Manania, Mumbai vs. DCIT-20(1), Mumbai

In the result, all the three appeals of the assessee are allowed

ITA 6180/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Jan 2025AY 2012-13

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Monika H. Pande
Section 132Section 133ASection 147Section 148Section 153CSection 69

sake of convenience. 2. The assessee is aggrieved by the decisions rendered by Ld CIT(A) in confirming the additions relating to unexplained investment by way of the Act in all the three years. 3. The facts relating to the above said issue are discussed in brief. The Revenue carried

Nimesh Umakant Manania, Mumbai vs. DCIT-20(1), Mumbai

In the result, all the three appeals of the assessee are allowed

ITA 6179/MUM/2024[2010-11]Status: DisposedITAT Mumbai24 Jan 2025AY 2010-11

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Monika H. Pande
Section 132Section 133ASection 147Section 148Section 153CSection 69

sake of convenience. 2. The assessee is aggrieved by the decisions rendered by Ld CIT(A) in confirming the additions relating to unexplained investment by way of the Act in all the three years. 3. The facts relating to the above said issue are discussed in brief. The Revenue carried

Nimesh Umakant Manania, Mumbai vs. DCIT-20(1), Mumbai

In the result, all the three appeals of the assessee are allowed

ITA 6178/MUM/2024[2011-12]Status: DisposedITAT Mumbai24 Jan 2025AY 2011-12

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Suchek AnchaliyaFor Respondent: Ms. Monika H. Pande
Section 132Section 133ASection 147Section 148Section 153CSection 69

sake of convenience. 2. The assessee is aggrieved by the decisions rendered by Ld CIT(A) in confirming the additions relating to unexplained investment by way of the Act in all the three years. 3. The facts relating to the above said issue are discussed in brief. The Revenue carried

Memani Investment & Finance Pvt Ltd, Mumbai vs. Income Tax Officer-10(2)(4), Mumbai

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

ITA 5531/MUM/2024[2011-12]Status: DisposedITAT Mumbai24 Jan 2025AY 2011-12

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarmemani Investment & V/S. Ito-Ward-10(2)(4),Mumbai बनाम Finance Pvt. Ltd. R. No. 211, Aayakar Bhavan, M. 2504, Shivshakti Apartments, K. Marg, Marine Lines, Mumbai- Vastu Lane, Sundervan 400 020 Complex, Andheri (West), Mumbai-400 053 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcm3332P Appellant/अपीलाथ" Respondent/"ितवादी ..

For Appellant: Shri Narayan Atal, ARFor Respondent: Shri Asif Karmali (Sr. DR)
Section 144Section 250

Tours and Travels,it was found that the assessee had received a sum of Rs 5 lakh an accommodation entry.This amount was treated as unexplained investment in the hands of the assessee by the ld.AO on account of its non compliance in the assessment proceedings which was completed

Sanjaybhai Arjunbhai Patel, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle-1, Surat

ITA 79/SRT/2023[2018-19]Status: DisposedITAT Surat23 Jan 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth

Section 254(1)Section 292C

restricting the addition to Rs.3,13,82,488/- as against addition of Rs.39,71,82,601/- made by the AO on account of unexplained investments in DKD Coins despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings and the assessee ... erred in deleting the addition of Rs.27,60,18,560/- made by the AO on account of unexplained investments in DKD Coins/lending DKD despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings and the assessee has failed to explain

Assistant Commissioner of Income Tax, Central Circle - 1, Surat vs. Shri Sanjaybhai Arjunbhai Patel, Surat

In the result, the ground No

ITA 211/SRT/2023[2018-19]Status: DisposedITAT Surat23 Jan 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth

Section 254(1)Section 292C

restricting the addition to Rs.3,13,82,488/- as against addition of Rs.39,71,82,601/- made by the AO on account of unexplained investments in DKD Coins despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings and the assessee ... erred in deleting the addition of Rs.27,60,18,560/- made by the AO on account of unexplained investments in DKD Coins/lending DKD despite the facts that addition has been made on the basis of incriminating details/document recovered during the search proceedings and the assessee has failed to explain

Krupal Vikrambhai Patel, Ahmedabad vs. The Income Tax Officer, Ward-6(1)(4), Ahmedabad

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

ITA 1508/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad23 Jan 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1508/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2011-12) बनाम/ Krupal Vikrambhai Patel The Income Tax Officer 4 Motibag Society, B/H. Ward – 6(1)(4), Vs. Choksi Park, Ahmedabad Bhaduatnagar, Maninagar, Ahmedabad, Gujarat - 380008 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Agmpp1472D (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri M. K. Patel, Advocate ""यथ" क" ओर से/Respondent By : Shri S K Agal, Sr. Dr Date Of Hearing 20/01/2025 Date Of Pronouncement 23/01/2025 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’), Dated 26.06.2024 For The Assessment Year 2011-12 In The Matter Of Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 (In Short ‘The Act’).

For Appellant: Shri M. K. Patel, AdvocateFor Respondent: Shri S K Agal, Sr. DR
Section 144Section 271(1)(c)

assessment, an addition of Rs.35,65,526/- was made ITA No. 1508/Ahd/2024 [Krupal Vikrambhai Patel vs. ITO] A.Y. 2011-12 - 2 – in respect of unexplained investment as well as unexplained cash deposits. The AO had also initiated penalty proceeding u/s.271(1)(c) of the Act in respect of this addition

Income Tax Officer, Gangtok vs. Bhumika Rai, Namchi, Sikkim

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

ITA 1581/KOL/2024[2017-18]Status: DisposedITAT Kolkata23 Jan 2025AY 2017-18

Bench: Sri Sanjay Garg & Sri Rakesh Mishra

Section 10Section 147Section 250Section 69Section 69A

assessee on addition treated as undisclosed income and unexplained income u/s 69A of the I.T. Act, 1961 and Unexplained Investment u/s 69 of the act allowing exemption u/s. 10(26AAA) of the I.T. Act on income which remained unexplained with regards to the sources of such income during the course

Ram Mohan Rao Darumagari, Secunderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

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

ITA 467/HYD/2019[2008-09]Status: DisposedITAT Hyderabad22 Jan 2025AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.467/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Shri Ram Mohan Rao Vs. Income Tax Officer Darumagari, Secunderabad Ward-15(1) Pan:Agapd7084P Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.466/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Late Vanaja Darumagari Vs. Income Tax Officer L/R Shri Ram Mohan Rao Ward-15(1) Darumagari, Secunderabad Hyderabad Pan:Akqpd6499Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Arun Lal, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 21/11/2024 घोषणा की तारीख/Pronouncement: 22/01/2025 आदेश/Order Per Vijay Pal Raothese Two Appeals By The Husband & Wife Are Directed Against Two Separate Orders Dated 10/01/2019 Of The Learned Cit (A)-7, Hyderabad For The A.Y.2008-09. The Issues

For Appellant: Shri Arun Lal, CAFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 132Section 139Section 148Section 69

Assessing Officer framed the assessment by making addition u/s 69 of the I.T. Act, 1961 of Rs.9,53,00,000/- as unexplained investment in purchase of land. Since the wife of the assessee was not a party to the sale deed dated 10/10/2007 whereby the land was purchased ... lakhs on account of investment made in the partnership firm. 3. On appeal, the learned CIT (A) has restricted the addition on account of unexplained investment in purchase of land to Rs.4,76,50,000/- by enhanced the assessment by a sum of Rs.10.00 Lakhs on account of investment made

Late Vanaja Darumagari L/R Ram Mohan Rao Darumagari, Hyderabad vs. Income Tax Officer, Ward-15(1), Hyderabad

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

ITA 466/HYD/2019[2008-09]Status: DisposedITAT Hyderabad22 Jan 2025AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.467/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Shri Ram Mohan Rao Vs. Income Tax Officer Darumagari, Secunderabad Ward-15(1) Pan:Agapd7084P Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.466/Hyd/2019 (िनधा"रण वष"/Assessment Year: 2008-09) Late Vanaja Darumagari Vs. Income Tax Officer L/R Shri Ram Mohan Rao Ward-15(1) Darumagari, Secunderabad Hyderabad Pan:Akqpd6499Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Arun Lal, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 21/11/2024 घोषणा की तारीख/Pronouncement: 22/01/2025 आदेश/Order Per Vijay Pal Raothese Two Appeals By The Husband & Wife Are Directed Against Two Separate Orders Dated 10/01/2019 Of The Learned Cit (A)-7, Hyderabad For The A.Y.2008-09. The Issues

For Appellant: Shri Arun Lal, CAFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 132Section 139Section 148Section 69

Assessing Officer framed the assessment by making addition u/s 69 of the I.T. Act, 1961 of Rs.9,53,00,000/- as unexplained investment in purchase of land. Since the wife of the assessee was not a party to the sale deed dated 10/10/2007 whereby the land was purchased ... lakhs on account of investment made in the partnership firm. 3. On appeal, the learned CIT (A) has restricted the addition on account of unexplained investment in purchase of land to Rs.4,76,50,000/- by enhanced the assessment by a sum of Rs.10.00 Lakhs on account of investment made

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Natarajan, Trichy

In the result, both the appeals stand dismissed

ITA 2641/CHNY/2024[2015-16]Status: DisposedITAT Chennai22 Jan 2025AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2641/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2015-16) Acit Shri Ramasamy Natarajan बनाम Central Circle-2 # 255, Ganapathy Nagar South, / Vs. Trichy. T.V. Kovil Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aabpn-8486-E (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.2640/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) Acit Shri Jayaraman Muthureddiar बनाम #14, Akila Gardens, 1St Street, Central Circle-2 Trichy. Ganapathy Nagar, T.V.Kovil / Vs. Trichy-620005. "थायीलेखासं./ जीआइआरसं./Pan/Gir No. Aadhj-0819-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr " थ" की ओर से/ Assessee By : Shri Y. Sridhar (Fca) & Ms. Varshha Sridhar (Ca)-Ld. Ars सुनवाई की तारीख/Date Of Hearing : 02-01-2025 घोषणा की तारीख /Date Of Pronouncement : 22-01-2025 आदेश / O R D E R

For Appellant: Shri Y. Sridhar (FCA) & Ms. VarshhaFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR
Section 131Section 132Section 143(3)Section 153CSection 69

carry cash being interest on loan to the assessee. On the basis of aforesaid facts, Ld. AO proceeded to make impugned addition of unexplained investment in the hands of the assessee. 3.4 During assessment proceedings, the assessee refuted the allegation of Ld. AO and stated that the proposed addition ... months from the date of search which was unacceptable. Finally, the loan amount of Rs.517.84 Lacs pertaining to this year was added as unexplained investment u/s 69 whereas interest amount of Rs.108 Lacs as allegedly received by the assessee was added as ‘Income from other sources’. Similar assessment was framed