“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

Jibu John, Pathanamthitta vs. DCIT Circle International Taxation, Trivandrum, Thiruvananthapuram

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

ITA 49/COCH/2024[AY 2015-16]Status: DisposedITAT Cochin21 Oct 2024

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Jibu John Dcit (International Taxation) Muruppel Veedu, Paranthal Room No. 28, 2Nd Floor Vs. Pathanamthitta 689518 Aayakar Bhavan, Kowdiar [Pan: Akqpj5758E] Thiruvananthapram 695003 (Appellant) (Respondent)

For Appellant: Shri Stephen George, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 69

assessee about the source of investment in the impugned property. Therefore, the AO treated the sum of Rs. 20,29,699/- as unexplained investment u/s 69 of the Act and added the same to the total income of the assessee. Aggrieved assessee carried the matter before ... other explanation of foreign currency and gold sale cannot be accepted in the absence of evidence. Thus, an amount of 20,29,699/- is unexplained investment u/s 69 in the hands of the assessee.” 3 Jibu John 4. Being aggrieved by the order of the CIT(IT), the assessee

Chemmagnat Kunjayyappan Rugmani, Thrissur vs. ACIT, Circle-2(1), Thrissur

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

ITA 351/COCH/2024[2017-2018]Status: DisposedITAT Cochin21 Oct 2024AY 2017-2018

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Chemmagnat Kunjayyappan Acit, Circle - 2(1) Rugmani Aayakar Bhavan Kunnappilly House Sakthanthampuran Nagar Vs. Peramangalam P.O. Thrissur 680001 Thrissur 680312 [Pan: Acupr8533R] (Appellant) (Respondent)

For Appellant: Ms. Preetha S. Nair, AdvocateFor Respondent: Ms. Leena Lal, Sr. D.R

Section 69

first issue raised by the assessee is that the learned CIT(A) erred in confirming the addition of Rs. 9,40,138/- as unexplained investment u/s 69 of the Income Tax Act, 1961 (the Act). 3. The assessee in the present case had made deposits ... withdrawal from pension used in making the impugned deposits. Thus, the AO treated the sum of Rs.9,50,138/- as unexplained investment u/s 69 of the Act and added to the total income of the assessee. Aggrieved assessee preferred an appeal to the learned CIT(A) who confirmed the same

Kalindee Estates Private Limited, Jaipur vs. Income Tax Officer, Jaipur

ITA 770/JPR/2024[2010-2011]Status: DisposedITAT Jaipur21 Oct 2024AY 2010-2011

For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. Anup Singh, Addl. CIT

Section 143(3)Section 147Section 68

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "B" JAIPUR डा० एस. सीतालक्ष्मी, न्यायिक

Rajkumar Lahori Shah Sahani, Mumbai vs. ITO 24(3)(5), Mumbai

In the result, the appeal of the assessee bearing ITA 3220/Mum/2024 is allowed for statistical purpose

ITA 3220/MUM/2024[2010-11]Status: DisposedITAT Mumbai21 Oct 2024AY 2010-11

Bench: Shri Anikesh Banerjee & Shri Omkareshwar Chidara

For Appellant: Shri Purav GindraFor Respondent: Shri Sunny Kachhwaha - SR DR

Section 10Section 143(3)Section 144Section 148Section 151Section 17Section 250Section 69BSection 80

facts and circumstances, Ld. CIT(A) has erred in confirming action of the Ld. Assessing Officer in making addition u/s 69B as unexplained investments of Rs. 1,00,00,000/- without considering the submissions made by the appellant. Such disallowance is bad in law and liable to be deleted ... disclosed in the return of income and Rs.1 crore for taxation of immovable property in absence of the source was treated as unexplained investment of the assessee and added back with the total income of the assessee which works out to total amount of Rs.1,01,37,250/-. Aggrieved

Ashok Kumar Gupta, Kolkata vs. ITO, Ward - 43(1), Kolkata

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

ITA 1081/KOL/2024[2017-2018]Status: DisposedITAT Kolkata18 Oct 2024AY 2017-2018

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2017-18

For Appellant: Deep Agarwal, AdvocateFor Respondent: Pradip Kumar Biswas, Addl. CIT

Section 133(6)Section 143(3)Section 250

explained. The balance SBNs deposited amounting to Rs.26,94,500/-(Rs. 32,85,000/- - Rs. 5,90,500/-) were treated as unexplained investment u/s 69A of the I.T. Act and the sum was added back to the total income. 5. Aggrieved with the assessment order, the assessee preferred an appeal ... under: Your Honour, all the four grounds are inclined to the sole issue of addition of Rs 26,94,500/- us 69A as Unexplained Investments; our submission is as follows: This instant appeal is against the order passed by the Commissioner of Income Tax (Appeals) dated 31/08/2023, confirming the addition

Castle Commodities Pvt. Ltd., Kolkata vs. ITO, Ward-6(1), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 1192/KOL/2023[2018-19]Status: DisposedITAT Kolkata18 Oct 2024AY 2018-19

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 133(6)Section 69

against the confirmation of addition of Rs. 91,96,15,112/- as made by the AO on account of unexplained investments u/s 69 of the Act. 4. Facts in brief are that the assessee filed return of income on 29.03.2019 declaring total income at NIL. The case of the assessee ... repayment thereof. The AO after examining the issue during the course of assessment proceedings came to the conclusion that the assessee has made unexplained investments by making loan to M/s Multiplier Enterprises Pvt. Ltd. of Rs. 44,68,00,000/- which was denied by the said party when

Rameshwar Patidar, Bhopal vs. ITO Rajgarh, Rajgarh

The appeal of the assessee is partly allowed for statistical purpose

ITA 41/IND/2024[2013-2014]Status: HeardITAT Indore18 Oct 2024AY 2013-2014

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Rameshwar Patidar, Income Tax Officer, 398-B Airport Road, Rajgarh Vs. Indra Vihar Colony, Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Baapp9201R Assessee By Shri S.S. Solanki, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 17.10.2024 Date Of Pronouncement 18.10.2024 O R D E R

Section 44ASection 69

circumstances of the case the Learned CIT Appeals has upheld the addition of Rs. 10,00,000/- made by the Learned Assessing Officer as unexplained investment under section 69 of the Income Tax Act, 1961 which is bad in law and erroneous. 2. That in the fact & Circumstances ... sustained by the CIT(A) of Rs.10,00,000/- on account of unexplained cash deposited in the bank account of the assessee treated as unexplained investment u/s 69 of the Act. The assessee is engaged in the of business of trading of sanitary and hardware items under the name

Meghna Nileshbhai Patni, Ahmedabad vs. The ITO, Ward-1(2)(3), Ahmedabad

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

ITA 216/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Divatia & Shri Samir Vora, A.RsFor Respondent: Shri Waghe Prasad Rao, Sr. DR

Section 250

NFAC [CIT(A)], Delhi (for short ‘NFAC’) upholding the addition of Rs.1,01,02,000/- made by A.O as unexplained investment towards purchase of immovable property is wholly illegal, unlawful and against the principles of natural justice. 2.1 The NFAC has grievously erred in law and or ono facts

Aadhya Reality, Vadodara vs. The Pr. CIT-1, Vadodara

ITA 133/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.132/Ahd/2022 िनधा"रण वष" /Assessment Year : 2017-18 Aadhya Infrastructure The Pr.Cit बनाम/ C/202, Manorath Complex Vadodara -1 V/S. Nr.Jalaram Nagar B/H. Mothers School Gotri Road Vadodara – 390 021 (Gujarat) Pan: Aayfa 4505 C & आयकर अपील सं /Ita No.133/Ahd/2022 िनधा"रण वष" /Assessment Year : 2017-18 Aadhya Reality The Pr.Cit बनाम/ 10, Gopal Nagar Vadodara-1 V/S. Gotri Vasna Road Vasna Vadodara – 390 007 (Gujarat) Pan: Aazfa 3693 G पीलाथ&/ (Appellants) '( यथ&/ (Respondent) Assessee(S) By : Ms. Urvashi Sodhan, Ar Revenue By : Shri Prithviraj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 09/10/2024 घोषणा की तारीख /Date Of Pronouncement: 17/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Respondent: Shri Prithviraj Meena, CIT-DR

Section 115BSection 133ASection 143(3)Section 263Section 270ASection 69A

income at the higher rate of 60% under Section 115BBE of the Act, as the income was neither unexplained under Section 69A nor considered unexplained investments. 7.4. Therefore, in light of the Dharti Estate judgment and the facts of the present case, we find that the PCIT erred in invoking

Aadhya Infrastructure, Vadodara vs. The Pr. CIT-1, Vadodara

ITA 132/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2017-18

For Respondent: Shri Prithviraj Meena, CIT-DR

Section 115BSection 133ASection 143(3)Section 263Section 270ASection 69A

Deputy Commissioner of Income Tax, Central Ciecle-2, Coimbatore vs. V Sathyamoorthy Co, Erode

ITA 1547/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Oct 2024AY 2020-21

For Respondent: Shri S. Sridhar (Advocate)- Ld.AR

Section 143(3)Section 153A

hands of the Appellant firm in the impugned order. 13. The CIT (Appeals) erred in sustaining the addition of Rs.91,90,00,000/- as unexplained investment u/s 69 of the Act on the presumption of unaccounted loans advanced by the Appellant without assigning proper reasons and justification ... related findings in the impugned order. 19. The CIT(Appeals) 20, Chennai failed to appreciate that in any event the assessment of such presumed unexplained investment in the hands of the Appellant firm thereby negating the addition made in this regard. 20. The CIT (Appeals) - 20, Chennai failed to appreciate

V Sathyamoorthy&Co, Erode vs. DCIT, Central Circle -2, Coimbatore

The appeal stands partly allowed

ITA 1025/CHNY/2024[2021-22]Status: DisposedITAT Chennai17 Oct 2024AY 2021-22

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.1025/Chny/2024 (िनधा*रण वष* / Assessment Year: 2021-22) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2 Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr

For Appellant: Shri S. Sridhar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR

Section 143(3)

related findings in the impugned order. 20. The CIT (Appeals) - 20, Chennai failed to appreciate that in any event the assessment of such presumed unexplained investment in the hands of the Appellant firm there by negating the addition made in this regard. 21. The CIT (Appeals) - 20, Chennai failed

V Sathyamoorthy&Co, Erode vs. DCIT, Central Circle -, Coimbatore

ITA 1024/CHNY/2024[2020-21]Status: DisposedITAT Chennai17 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1024/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2 Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.1547/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) Dcit M/S. V. Sathyamoorthy & Co., बनाम/ Central Circle-2 41, Patel Road, Near Blood Bank, Vs. Coimbatore. Erode-638 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 17-10-2024 आदेश / O R D E R

For Appellant: Shri S. Sridhar (Advocate)- Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT)-Ld. DR

Section 143(3)Section 153A

hands of the Appellant firm in the impugned order. 13. The CIT (Appeals) erred in sustaining the addition of Rs.91,90,00,000/- as unexplained investment u/s 69 of the Act on the presumption of unaccounted loans advanced by the Appellant without assigning proper reasons and justification ... related findings in the impugned order. 19. The CIT(Appeals) - 20, Chennai failed to appreciate that in any event the assessment of such presumed unexplained investment in the hands of the Appellant firm thereby negating the addition made in this regard. 20. The CIT (Appeals) - 20, Chennai failed to appreciate

Swaroop Narain Shiv Narain, Jaipur, Rajasthan vs. ACIT, Central Circle - 3, Jaipur, Rajasthan

ITA 517/JPR/2024[2018-19]Status: DisposedITAT Jaipur17 Oct 2024AY 2018-19

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Arvind Kumar, CIT-DR

Section 115BSection 127Section 143(2)Section 143(3)Section 69Section 69B

course of search the value of excess stock of Rs.22,68,327/- is being added to the total income of the assessee as unexplained investment u/s 69 r.w.s. 115BBE of the IT Act, 1961 out of its undisclosed income. 4. Aggrieved from the order of Assessing Officer, assessee preferred

Rohit Ladiwala, Jaipur vs. DCIT, Central Circle-1, Jaipur

ITA 339/JPR/2024[2015-16]Status: DisposedITAT Jaipur17 Oct 2024AY 2015-16

For Appellant: Sh. Vinod Kumar Gupta, CAFor Respondent: MS. Alka Gautam, CIT(V.H)

Section 132(1)Section 139Section 143(2)Section 143(3)Section 153ASection 68Section 69

respect of gift of jewellery received from his maternal grandmother alleging the same to be unexplained investment. The addition so made is wrong on law as well as on the facts of the case, unjustified, excessive, unreasonable and kindly be deleted in full. 4. Ld.CIT (A) erred ... hands of the assessee comprising of addition on account of unexplained jewellery shown under the garb of gift, which is actually unexplained investment of the assessee is being added as unexplained investment u/s 69 r.w.s. 115BBE of Rs. 13,76,000/-. And Addition on account of unexplained cash credit

ACIT 16.3, Mumbai vs. Dr. Sangeeta Ganpat Sawant, Mumbai

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

ITA 3743/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Oct 2024AY 2018-19

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Sanjay ParikhFor Respondent: Shri BhangepatilPushkaraj Ramesh, Sr.DR

Section 143Section 143(2)Section 143(3)Section 250Section 69

amount of Rs.3,33,25,590 was added to the ITA No.3743/Mum/2024 (AY. 2018-19) JZ total income of the assessee as an unexplained investment under section 69 of the Act. 5. The learned CIT(A), vide impugned order, allowed the ground raised by the assessee on this issue ... made by the assessee during the year under consideration, we find no merit in treating the entire sum as an unexplained investment in the year under consideration. Since the assessee has duly explained the source of the payment made during the year under consideration, we find no infirmity

Ganesh Das Taneja, Najibabad vs. Deputy Commissioner of Income Tax, Central Circle, Moradabad

In the result, Appeals of the Assessee in ITA No

ITA 2621/DEL/2023[AY 2011-12]Status: DisposedITAT Delhi17 Oct 2024

Bench: Sh. Pradip Kumar Kedia & Shri Yogesh Kumar U.S.I.T.A. No. 2621/Del/2023 (A.Y 2011-12) Ganesh Das Taneja, Deputy Commissioner Ajmal Khan Road, Of Income Tax Vs. Najibabad, Central Circle, Income Uttar Pradesh, 246763, Tax Office, Civil Lines Moradabad, Uttar Pan No. Aawpt0826H Pradesh (Appellant) (Respondent) I.T.A. No. 2613/Del/2023 (A.Y 2012-13) Ganesh Das Taneja, Deputy Commissioner Ajmal Khan Road, Of Income Tax Vs. Najibabad, Central Circle, Income Uttar Pradesh, 246763, Tax Office, Civil Lines Moradabad, Pan No. Aawpt0826H Uttar Pradesh (Appellant) (Respondent)

For Appellant: Sh. Ganesh Das Taneja, Self and Sh. Vidit Taneja, CA

Section 143(3)Section 153CSection 69

facts and circumstances of the case, the Ld. CIT has erred in confirming the addition made of Rs. 48,00,000/- on account of unexplained investment u/s 69 of the Income Tax Act, 1961 ('the Act') by the AO's consideration that the said payment was made in cash ... circumstances of the case, the Ld. CIT has erred in confirming the addition of Rs. 5,20,000/- paid through banking channel as unexplained investment u/s 69 of the Income Tax Act, 1961 ('the Act'). The addition so confirmed being wrong and unjustified, the same, therefore, requires to be deleted

Ganesh Das Taneja, Najibabad vs. Deputy Commissioner of Income Tax, Central Circle, Moradabad

In the result, Appeals of the Assessee in ITA No

ITA 2613/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2024AY 2012-13

For Appellant: Sh. Ganesh Das Taneja, Self and Sh. Vidit Taneja, CA

Section 143(3)Section 153CSection 69

Asrafkhan Kalndrkhan Pathan, Ahmedabad vs. The ACIT, Circle-1(3), Ahmedabad

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

ITA 1042/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad16 Oct 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1042/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Asrafkhan Kalndrkhan Pathan The Acit बनाम Sardar Apartment Circle-1(3), / Kanch Ni Masjid Ahmedabad V/S. Jamalpur Ahmedabad – 380 001 (Gujarat) "थायी लेखा सं./Pan: Agcpp 7537 R अपीलाथ&/ (Appellant) '( यथ&/ (Respondent) Assessee By : Shri B.R. Popat, Ar Revenue By : Shri Prateek Sharma, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/10/2024 घोषणा की तारीख /Date Of Pronouncement: 16/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri B.R. Popat, ARFor Respondent: Shri Prateek Sharma, Sr.DR

Section 142(1)Section 143(2)Section 143(3)Section 68Section 69

demonetization period. Rs.11,74,780/- was disallowed as unexplained agricultural income under section 68 of the Act. Rs.32,67,800/- was added as unexplained investment under section 69 of the Act, representing the purchase of a vehicle, including registration fees and insurance. Asrafkhan Kalndrkhan Pathan vs. ACIT Asst. Year ... facts in confirming the addition of Rs.32,67,800/-made by the AO, which was done by treating purchase of a vehicle as unexplained investment, thus chargeable to tax under section 69 of the Act. 4. Without prejudice and assuming though not admitting about even slightest justification

M/S Arrowspace Tradecom Pvt. Ltd., Kolkata vs. ITO, Ward-10(2), Kolkata

In the result, in light of the discussion made above, this appeal is dismissed

ITA 344/KOL/2024[2016-17]Status: DisposedITAT Kolkata16 Oct 2024AY 2016-17

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 234BSection 234DSection 271(1)(c)

produce correct details before the honorable member. 4. For that the Ld. AO erred in assessing Rs. 4,57,06,000/- as unexplained investment without issuing show cause notice. For that under the facts and circumstances, the addition made is liable to be deleted. 5. That the Ld. AO erred