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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

Subbiyan Rathinakumar, Coimbatore vs. ITO, Ncw-3(2), Coimbatore

In the result, appeal filed by the assessee in ITA

ITA 1654/CHNY/2024[2015-16]Status: DisposedITAT Chennai06 Dec 2024AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 133ASection 148

assessee as under: Income returned Rs.41,20,890/- Less: Income added under "Other sources Rs.25,00,000/- other income" Rs. 16,20,890/- Add: Unexplained investments - under sec.69 Rs.35,50,000/- To be taxed under sec.115BBE Assessed Income Rs.51,70,890/- Agricultural income Rs. 1,20,000/- 13. We note ... Rs.41,20,000/- and reduced the returned income at Rs.16,20,890/- and thereafter, added Rs.35,50,000/- u/s.69 of the Act as unexplained investment, which action can’t be countenanced when the assessee has offered in his RoI Rs.41,20,890/- and in the computation of income has clearly

Subbiyan Rathinakumar, Coimbatore vs. ITO, Ncw-3(3), Coimbatore

In the result, appeal filed by the assessee in ITA

ITA 1641/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Dec 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 133ASection 148

assessee as under: Income returned Rs.41,20,890/- Less: Income added under "Other sources Rs.25,00,000/- other income" Rs. 16,20,890/- Add: Unexplained investments - under sec.69 Rs.35,50,000/- To be taxed under sec.115BBE Assessed Income Rs.51,70,890/- Agricultural income Rs. 1,20,000/- 13. We note ... Rs.41,20,000/- and reduced the returned income at Rs.16,20,890/- and thereafter, added Rs.35,50,000/- u/s.69 of the Act as unexplained investment, which action can’t be countenanced when the assessee has offered in his RoI Rs.41,20,890/- and in the computation of income has clearly

Mahesh Lingappa, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Bangalore

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

ITA 1400/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Dec 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Ms. Pratibha .R, Advocate
Section 143(1)Section 147Section 69A

assessing officer with regard to the documents submitted by the assessee in support of their claim. The only reason for treating the said as unexplained investment is that the assessee had received the SBN notes and deposited the same into their bank account and therefore the same were treated ... unexplained investment u/s. 69A of the Act. In the previous paragraphs, we have extracted the provision and the conditions to attract the section 69A of the Act. In the present case, it is an admitted fact that the assessee is the owner of the money and such money was also

Hanubhai Devabhai Rathod, Ahmedabad vs. The Income Tax Officer, Ward-1, Anand

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

ITA 669/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 668 & 669/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2016-17 & 2017-18) बनाम/ Hanubhai Devabhai Income Tax Officer Rathod Ward 1, Anand Vs. C/O. M S Chhajed & Co. Ca, “Kamal Shanti” Nr. Sardar Patel Statue, Ahmedabad - 380014 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abrpr2912C (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Mahesh Chhajed, A.R. ""यथ" क" ओर से/Respondent By : Shri Rignesh Das, Sr. Dr Date Of Hearing 26/11/2024 Date Of Pronouncement 05/12/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Two Appeals Are Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’), Dated 09.03.2024 For The Assessment Years 2016- 17 & 2017-18 Respectively. As The Facts Of The Cases Are Identical, They Were Heard Together & Are Being Disposed Of Vide This Common Order.

For Appellant: Shri Mahesh Chhajed, A.RFor Respondent: Shri Rignesh Das, Sr. DR
Section 143(1)Section 147Section 69Section 69A

Therefore, the AO made additions in respect of total credit of Rs.24,63,386/- in the bank account as well as in respect of unexplained investment of Rs.24,35,800/- in the shops. The assessment was completed u/s.147 r.w.s. 144 of the Act on 31.03.2022 at total income of Rs.56

Hanubhai Devabhai Rathod, Ahmedabad vs. The Income Tax Officer, Ward-1, Anand

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

ITA 668/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2016-17

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 668 & 669/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2016-17 & 2017-18) बनाम/ Hanubhai Devabhai Income Tax Officer Rathod Ward 1, Anand Vs. C/O. M S Chhajed & Co. Ca, “Kamal Shanti” Nr. Sardar Patel Statue, Ahmedabad - 380014 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abrpr2912C (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Mahesh Chhajed, A.R. ""यथ" क" ओर से/Respondent By : Shri Rignesh Das, Sr. Dr Date Of Hearing 26/11/2024 Date Of Pronouncement 05/12/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Two Appeals Are Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’), Dated 09.03.2024 For The Assessment Years 2016- 17 & 2017-18 Respectively. As The Facts Of The Cases Are Identical, They Were Heard Together & Are Being Disposed Of Vide This Common Order.

For Appellant: Shri Mahesh Chhajed, A.RFor Respondent: Shri Rignesh Das, Sr. DR
Section 143(1)Section 147Section 69Section 69A

Therefore, the AO made additions in respect of total credit of Rs.24,63,386/- in the bank account as well as in respect of unexplained investment of Rs.24,35,800/- in the shops. The assessment was completed u/s.147 r.w.s. 144 of the Act on 31.03.2022 at total income of Rs.56

Amey Pravinbhai Bhahmbhatt, Ahmedabad vs. The ITO, Ward-7(1)(5), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 1587/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2011-12

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1587/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2011-12) बनाम/ Amey Pravinbhai Ito Brahmbhatt Ward-7(1)(5), Ahmedabad Vs. C/O. Divyang J Shah 201, 2Nd Floor, Devashish Complex, Nr. Regenta Central Antarim Hotel, Off. C. G. Road, Ahmedabad - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aelpb9923J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Divyang Shah, A.R. ""यथ" क" ओर से/Respondent By : Shri Sudhakar Verma, Sr. Dr Date Of Hearing 21/11/2024 Date Of Pronouncement 05/12/2024 O R D E R Per Shri Narendra Prasad Sinha, Am:

For Appellant: Shri Divyang Shah, A.RFor Respondent: Shri Sudhakar Verma, Sr. DR
Section 144Section 147Section 148

facts and in circumstances of the case and in law, Ld. CIT(A) has erred in confirming addition of Rs. 6,37,000/- as unexplained investment? 3. Whether, on facts and in circumstances of the case and in law, Ld. Assessing officer has erred in issuing notice ... assessee in this regard is infructuous and is, therefore, dismissed. 6. The next ground pertains to addition of Rs.6,37,000/- on account of unexplained investment. In the course of assessment, the AO found that the assessee had paid sum of Rs.6,37,000/- to KIFS Trade Capital

J K Associates, Ahmedabad vs. The ITO, Ward-4(2)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 1200/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1200/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2017-18) बनाम/ J K Associates Ito Vikram Plaza, Nr. Ward 4(2)(1), Ahmedabad Vs. Vishwakarma Mandir, Chandlodia, Ahmedabad - 382481 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aalfj9737G (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Shri Rignesh Das, Sr. Dr 25/11/2024 Date Of Hearing Date Of Pronouncement 05/12/2024 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 03.06.2024 For The Assessment Year 2017-18. 2. The Brief Facts Of The Case Are That No Return Of Income Was Filed By The Assessee For The A.Y. 2017-18. An Information Was Received By The Ao That The Assessee Firm Had Purchased Immovable Property Of Rs.1 Crore During The F.Y. 2016-17 Relevant To A.Y. 2017-18. In The Absence Of Any Return Filed By The Assessee, The Source Of Investment By The Assesse In The Immovable Property Remained Unexplained. Therefore, The Proceedings Under Section 147 Of The Income Tax Act, 1961 (In Short

For Appellant: Shri Parin Shah, A.RFor Respondent: Shri Rignesh Das, Sr. DR
Section 115BSection 133(6)Section 147Section 148Section 234ASection 271ASection 68

reopened assessment proceeding was completed u/s.147 r.w.s. 144B of the Act on 25.03.2022, wherein addition of Rs.1 Crore was made in respect of unexplained investment in the immovable property. 3. Aggrieved with the order of the AO, the assessee had filed an appeal before the First Appellate Authority, which ... decided by the Ld. CIT(A) vide the impugned order. The addition as made by the AO in respect of unexplained investment in the property was confirmed by the Ld. CIT(A) and the appeal of the assessee was dismissed. 4. Now, the assesse is in second appeal before

Narasimha Reddy Chimmula, Gummadidala Village vs. ACIT, Central Circle-2(4), Hyderabad

In the result, the appeals of the assessee for the A

ITA 190/HYD/2024[2021-22]Status: DisposedITAT Hyderabad05 Dec 2024AY 2021-22

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

For Appellant: Shri M.V.Prasad, ARFor Respondent: Ms. Kavitha Rani, DR
Section 115BSection 271ASection 44ASection 69

agricultural produce received from Government of Telangana through banking channels. 3. The Learned CIT(A) also erred in treating the agricultural income estimated as unexplained investment and accordingly erred in taxing the same under the provisions of Section 115BBE of the I.T.Act since the Assessing Officer and CIT(A) have

Narasimha Reddy Chimmula, Gummadidala Village vs. ACIT, Central Circle - 2(4), Hyderabad

In the result, the appeals of the assessee for the A

ITA 189/HYD/2024[2020-21]Status: DisposedITAT Hyderabad05 Dec 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

For Appellant: Shri M.V.Prasad, ARFor Respondent: Ms. Kavitha Rani, DR
Section 115BSection 271ASection 44ASection 69

agricultural produce received from Government of Telangana through banking channels. 3. The Learned CIT(A) also erred in treating the agricultural income estimated as unexplained investment and accordingly erred in taxing the same under the provisions of Section 115BBE of the I.T.Act since the Assessing Officer and CIT(A) have

Laxmi Nanda Kishore Velegatla, Chennai vs. DCIT, CC-1(4), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1727/CHNY/2024[2021-22]Status: DisposedITAT Chennai05 Dec 2024AY 2021-22

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1727/Chny/2024 िनधा"रण वष" / Assessment Year: 2021-22 Laxmi Nanda Kishore Velegatla, Deputy Commissioner Of Kg Signature City, D-2 Block, V. Income Tax, Floor -12A, Flat No.9, 200 Feet Central Circle -1(4), Bypass Road, Adjacent Service Chennai – 600 034. Road, Near Lalitha Mugambigai Medical College & Hospital, Maduravoyal, Chennai – 600 095. [Pan: Acopv-3242-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. P. Ranga Ramanujam, Ca : Ms. Swapna Nanu Ambatt, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 11.11.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.12.2024

For Appellant: Mr. P. Ranga Ramanujam, CA
Section 115Section 139(4)Section 142(1)Section 143(3)Section 69

erred in not appreciating that the impugned addition made by AO in the assessment order under the head Unexplained Investment is neither valid in law nor on merits. 6 The Ld. CIT A has erred in not appreciating that the addition made ... with the submissions of the assessee and concluded the assessment by making an addition of Rs.12,14,570/- u/s. 69 of the Act as unexplained investment by passing an order u/s. 143(3) of the Act dated 24.09.2022, by holding as under: “6. On perusal of the list of jewellery

Rajesh Atalram Rupani, Bandra vs. Deputy Commissioner of Income Tax - Circle - 19(3), Mumbai

ITA 5180/MUM/2024[2020-21]Status: DisposedITAT Mumbai05 Dec 2024AY 2020-21

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri R.R. Makwana, Sr. DR
Section 69

income of the assessee at Rs. 1,06,63,667/- wherein the AO made addition of Rs. 73,24,686/- under section 69 towards unexplained investments and an addition of Rs. 11,43,750/- towards interest income as appearing in Form 26AS. Aggrieved the assessee filed further appeal before

Income Tax Officer, Vashi, Navi Mumbai vs. Mahesh K Shavdia HUF, Mumbai

ITA 2214/MUM/2024[2011]Status: DisposedITAT Mumbai05 Dec 2024

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhanassessment Year : 2011-12 Income Tax Officer, Mahesh K. Shavdia Huf, Room No. 413, 4Th Floor, 27/28, Kailash Niwas No. 2, Tower No. 6, Vs. R.B.Mehta Marg, Vashi Railway Station Ghatkopar (East), Complex, Mumbai Navi Mumbai Pan : Aahhm1877L (Appellant) (Respondent) Assessee By : Shri Sanjay R. Parikh Revenue By : Shri Krishna Kumar, Sr. Dr Date Of Hearing : 08/11/2024 Date Of Pronouncement : 05/12/2024

For Appellant: Shri Sanjay R. ParikhFor Respondent: Shri Krishna Kumar, Sr. DR
Section 132(4)Section 133(6)Section 148Section 69

28/06/2013 executed between M/s Nish Developers Pvt. Ltd and Kantilal N. Shavadia, HUF and Mahesh K. Shavadia, HUF treated Rs.2,41,40,000/- as unexplained investment u/s 69 of the Act and completed the assessment. However, the assessee during the assessment proceedings as well as in the present appellate proceeding

Assistant Commissioner of Income Tax, Circle-1(1)(1), Meerut vs. Omnibus Healthcare India Private Limited, Rajdhani Enclave, Delhi

Appeal is dismissed in above terms

ITA 827/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Dec 2024AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganeshita No. 827/Del/2024 : Asstt. Year : 2017-18 Acit, Vs Omnibus Healthcare India Pvt. Ltd. Circle-1(1)(1), Shop No. 3, Plot No. 2, Near Bal Meerut, Uttar Pradesh-250001 Mandir School Delhi, Delhi-110092 (Appellant) (Respondent) Pan No. Aacco0534A Assessee By : Sh. Ved Jain, Adv. & Sh. Ayush Garg, Ca Revenue By : Sh. B. S. Anand, Sr. Dr Date Of Hearing: 25.11.2024 Date Of Pronouncement: 05.12.2024 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Order Of Cit(A)/Nfac, Delhi Dated 22.12.2023 In Din & Order No. Itba/Nfac/S/250/2023- 24/1059017134(1) In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. B. S. Anand, Sr. DR
Section 142ASection 143(3)Section 69

facts in deleting the addition ot the tune of Rs.5,30,96,798/- made by the AO under the head “Unexplained Investment u/s 69 of the Income Tax Act, 1961, as the addition was made on the basis of valuation report submitted by the Valuation Officer under section 142A ... 827/Del/2024) with assessee’s appeal ITA No. 664/Del/2024 wherein both of them are aggrieved against CIT(A)/NFAC’s action partly upholding section 69 unexplained investment of Rs.6,61,86,825/- only to the extent of Rs.1,30,90,027/-, leaving the Revenue aggrieved and is in appeal before

Juned Yusuf Shethwala, Vadodara vs. The Income Tax Officer, Ward-3(1)(1), Vadodara

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

ITA 1550/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2010-11

Bench: Ms. Suchitra Kambleआयकर अपील सं./Ita No. 1550/Ahd/2024 िनधा"रण वष"/Asstt. Year: 2010-2011 Juned Yusuf Shethwala, The Income Tax Officer, बनामVs 1/2 Outside Gajrawadi Ward-3(1)(1), . Police Choki, Vadodara. Wadi Navapura Naka Wadi, Vadodara-390012. Pan: Bbnps7003Q

For Appellant: Shri Vipul Khandhar, ARFor Respondent: Shri N J Vyas, Sr. DR
Section 147Section 148Section 250Section 69

being unexplained payment u/s 69 of IT Act, 1961. 3. The learned CIT (Appeal), NFAC, Delhi erred in confirming the addition of Rs.512050/- being unexplained investment u/s 69 of IT Act, 1961. 4 The learned CIT (Appeal), NFAC, Delhi erred in confirming the addition of Rs 30000/- being deduction under

Guru Krishnanand Charitable Trust, Coimbatore vs. DCIT, Central Circle-1, Coimbatore

In the result, the appeals filed by the assesses in ITA Nos

ITA 129/CHNY/2024[2013-14]Status: DisposedITAT Chennai04 Dec 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.127, 128 & 129/Chny/2024 (िनधा"रणवष" / Assessment Years: 2011-12, 2012-13 & 2013-2014) Guru Krishnanand Charitable Trust, Vs. The Deputy Commissioner Of 157, P.M. Swamy Colony, Income Tax, 5Th Street, Central Circle 1, Coimbatore 641 002. Coimbatore [Pan: Aaatg 4923A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. N. Arjun Raj, Advocate ""यथ" क" ओर से /Respondent By : Ms. R. Anita, Irs, Addl. Cit.

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anita, IRS, Addl. CIT
Section 12ASection 132Section 142(1)Section 144Section 148Section 271F

Unexplained Cash credits in the Bank accounts Rs.72,63,100/- ii Transfer of money from trust account to personal Rs.23,35,625/- accounts iii Unexplained investment Rs.32,50,000/- Assessed Income u/s 144 Rs. 1,28,48,725/- Aggrieved by the order, the assessee preferred an appeal before ... partly allowed the ground raised by the assessee. 6. The last ground raised by the assessee is with regard to unexplained investment of Rs.32,50,000/-. Since the assessee has explained the source for Rs.20,00,000/-, the ld. CIT(A) deleted the addition of Rs.20,00,000/- and confirmed

Guru Krishnanand Charitable, Coimbatore vs. DCIT, Central Circle-1 Cbe, Coimbatore

In the result, the appeals filed by the assesses in ITA Nos

ITA 128/CHNY/2024[2012-13]Status: DisposedITAT Chennai04 Dec 2024AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.127, 128 & 129/Chny/2024 (िनधा"रणवष" / Assessment Years: 2011-12, 2012-13 & 2013-2014) Guru Krishnanand Charitable Trust, Vs. The Deputy Commissioner Of 157, P.M. Swamy Colony, Income Tax, 5Th Street, Central Circle 1, Coimbatore 641 002. Coimbatore [Pan: Aaatg 4923A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. N. Arjun Raj, Advocate ""यथ" क" ओर से /Respondent By : Ms. R. Anita, Irs, Addl. Cit.

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anita, IRS, Addl. CIT
Section 12ASection 132Section 142(1)Section 144Section 148Section 271F

Unexplained Cash credits in the Bank accounts Rs.72,63,100/- ii Transfer of money from trust account to personal Rs.23,35,625/- accounts iii Unexplained investment Rs.32,50,000/- Assessed Income u/s 144 Rs. 1,28,48,725/- Aggrieved by the order, the assessee preferred an appeal before ... partly allowed the ground raised by the assessee. 6. The last ground raised by the assessee is with regard to unexplained investment of Rs.32,50,000/-. Since the assessee has explained the source for Rs.20,00,000/-, the ld. CIT(A) deleted the addition of Rs.20,00,000/- and confirmed

Guru Krishnanand Charitable Trust, Coimbatore vs. DCIT, Central Circle-1, Coimbatore

In the result, the appeals filed by the assesses in ITA Nos

ITA 127/CHNY/2024[2011-12]Status: DisposedITAT Chennai04 Dec 2024AY 2011-12

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.127, 128 & 129/Chny/2024 (िनधा"रणवष" / Assessment Years: 2011-12, 2012-13 & 2013-2014) Guru Krishnanand Charitable Trust, Vs. The Deputy Commissioner Of 157, P.M. Swamy Colony, Income Tax, 5Th Street, Central Circle 1, Coimbatore 641 002. Coimbatore [Pan: Aaatg 4923A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. N. Arjun Raj, Advocate ""यथ" क" ओर से /Respondent By : Ms. R. Anita, Irs, Addl. Cit.

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anita, IRS, Addl. CIT
Section 12ASection 132Section 142(1)Section 144Section 148Section 271F

Unexplained Cash credits in the Bank accounts Rs.72,63,100/- ii Transfer of money from trust account to personal Rs.23,35,625/- accounts iii Unexplained investment Rs.32,50,000/- Assessed Income u/s 144 Rs. 1,28,48,725/- Aggrieved by the order, the assessee preferred an appeal before ... partly allowed the ground raised by the assessee. 6. The last ground raised by the assessee is with regard to unexplained investment of Rs.32,50,000/-. Since the assessee has explained the source for Rs.20,00,000/-, the ld. CIT(A) deleted the addition of Rs.20,00,000/- and confirmed

Chaitalee Sachin Deokar, Mumbai vs. Commissioner of Income Tax, -It -2, Mumbai

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

ITA 2806/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Dec 2024AY 2013-14

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 143(3)Section 263Section 69Section 69BSection 69C

leave alone an officer of the Revenue in a quasi judicial role like the AO, could have reached such a conclusion that for taxing unexplained investment there is an onus on the Revenue to seek out cash withdrawals from bank accounts which are duly disclosed to the department ... paid entire amount of flat in cash, impugned reopening notice was unjustified. Section 69, read with section 148A, of the Income-tax Act, 1961 Unexplained investments on (Illustrations) Assessment year 2015-16 - Assessing Officer issued a on the notice under section 148A(b) on ground that during search operation carried

Sh. Surinder Kumar, Rajpura vs. ACIT, Circle, Patiala

In the result, all the three captioned appeals are allowed

ITA 435/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh03 Dec 2024AY 2018-19

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 131Section 133ASection 54BSection 69

difference in amount surrendered by the assessee and the actual valuation of the building and land of Simran Dhaba treating it to be unexplained investment u/s 69-which is arbitrary and unjustified. 5. That the appellant craves leave to add or amend the grounds of appeal before the appeal ... said Simran Dhaba. The Assessee and his family members in respect of the said construction had offered Rs. 78 lacs on account of unexplained investment. Since the Assessee had contributed 1/3rd of the said amount, the Assessee, therefore, had offered Rs. 26 lacs as unexplained investment made on the said

Sh. Pawan Kumar, Rajpura vs. ACIT, Circle, Patiala

In the result, all the three captioned appeals are allowed

ITA 434/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh03 Dec 2024AY 2018-19

Bench: Shri Sanjay Gargआयकर अपील सं./ Ita No. 433 /Chd/2023 "नधा"रण वष" / Assessment Year : 2018-19 बनाम Shri Mohinder Kumar, The Acit, #371, Dalima Vihar, Circle, Rajpaura 140401 Patiala Punjab "थायी लेखा सं./Pan No: Aenpk2131D अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 131Section 133ASection 54BSection 69

difference in amount surrendered by the assessee and the actual valuation of the building and land of Simran Dhaba treating it to be unexplained investment u/s 69-which is arbitrary and unjustified. 5. That the appellant craves leave to add or amend the grounds of appeal before the appeal ... said Simran Dhaba. The Assessee and his family members in respect of the said construction had offered Rs. 78 lacs on account of unexplained investment. Since the Assessee had contributed 1/3rd of the said amount, the Assessee, therefore, had offered Rs. 26 lacs as unexplained investment made on the said