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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

The ACIT Central-3, Indore vs. Jarnalbeer Singh Bhatia, Khandwa

ITA 228/IND/2023[2018-19]Status: DisposedITAT Indore18 Sept 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 153ASection 69

erred in making notional addition in the form of cash loans amounting to Rs. 50,05,000/- as peak of unexplained investment u/s 69 of Income-tax Act, 1961. 2. That on the facts and in the circumstances of the case, Ld. AO and Ld. CIT(A) has erred ... erred in making notional addition in the form of cash loans amounting to Rs. 2,31,02,579/- as peak of unexplained investment u/s 69 of Income-tax Act, 1961. 2. That on the facts and in the circumstances of the case, Ld. AO and Ld. CIT(A) has erred

Jarnalbeer Singh Bhatia, Khandwa vs. The ACIT Central-3, Indore

ITA 226/IND/2023[2018-19]Status: DisposedITAT Indore18 Sept 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniit(Ss)A Nos.19 To 23/Ind/2023 & Ita No.226/Ind/2023 Ays : 2013-14 To 2018-19 Jarnalbeer Singh Bhatia, Dcit/Acit, बनाम/ Bhatia Transport (Central)-3, Vs. Services, Indore. Old Indore Lines, Pandhana Road, Khandwa (Pan: Aixpb4565C) (Assessee/Appellant) (Revenue/Respondent)

Section 132Section 153ASection 69

erred in making notional addition in the form of cash loans amounting to Rs. 50,05,000/- as peak of unexplained investment u/s 69 of Income-tax Act, 1961. 2. That on the facts and in the circumstances of the case, Ld. AO and Ld. CIT(A) has erred ... erred in making notional addition in the form of cash loans amounting to Rs. 2,31,02,579/- as peak of unexplained investment u/s 69 of Income-tax Act, 1961. 2. That on the facts and in the circumstances of the case, Ld. AO and Ld. CIT(A) has erred

Rathanlal Choudhary, Chennai vs. ITO, Chennai

In the result, appeal filed by the assessee is allowed

ITA 1409/CHNY/2024[2017-18]Status: DisposedITAT Chennai18 Sept 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1409/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 V. Mr. Rathanlal Choudhary, The Ito, 229/201, Periyar Pathai, Ncw-19(7), Choolaimedu, Chennai. Chennai-600 094. [Pan: Aczpc 3252 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 69

establish his explanation about the nature & source of SBNs; and therefore, he added SBNs deposited to the tune of Rs.27,46,600/- as unexplained investment u/s.69 of the Act. 4. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who confirmed the action of the AO on the same ... same or his explanation is not found satisfactory by the AO, then the AO can treat the value of the investment as unexplained investment u/s.69 of the Act. However, in this case, we note that the assessee has recorded the cash/SBNs as receipts from his customers/borrowers which fact is discernable

Ashok Kumar Verma, Chomehla, Jhalawar vs. ACIT, Kota

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

ITA 529/JPR/2024[2017-18]Status: DisposedITAT Jaipur17 Sept 2024AY 2017-18

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

For Appellant: Shri Nikhelesh Kataria (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 129Section 142(1)Section 143(2)Section 143(3)Section 69A

decrease in profitability compare to previous year, therefore, total cash amounting to Rs.27,00,000/- deposited during the demonetization period has been treated as unexplained investment and made addition u/s 69A of the Act. It is specific case of the assessee that the year under consideration was the first year

Income Tax Officer-16(3)(1), Mumbai vs. Ms. Shabnam Laiq Ahmed Khan, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 3849/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Sept 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Swapnil Savant, Sr. DR
Section 50CSection 56(2)(vii)Section 69

investment. Accordingly, the AO added 1/4th share of the purchase value of Rs. 4,93,43,822/- i.e. Rs. 1,23,35,955/- as unexplained investment under section 69 of the Act. The AO further held that the value of the property on the date of registration ... that the claim of the assessee that it is her father who has purchased the flats is not substantiated. The AO made addition towards unexplained investments, under section 56(2)(vii)(b) and also STCG. The CIT(A) deleted the additions based on the submissions made by the assessee before

Sharada Radhakrishnan, Kolkata vs. I.T.O., Ward - 25(4), Kolkata

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

ITA 1026/KOL/2024[2010-2011]Status: DisposedITAT Kolkata13 Sept 2024AY 2010-2011

Bench: Pradip Kumar Choubey & Sri Sanjay Awasthi

Section 143(3)Section 147Section 69A

cancelled/set- aside/quashed. 2. For that in the facts and circumstances of the case and in law, the addition of Rs. 698,975 as alleged unexplained investment u/s. 69A is wrong, erroneous, arbitrary, perverse, misconceived, excessive and deserves to be deleted/reduced. 3. For that in the facts and circumstances

Shivasharane Hemaraddi Mallamma Pattin Sahakar Sangh Ni Talikoti, Vijayapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

ITA 1436/BANG/2024[2017-18]Status: DisposedITAT Bangalore13 Sept 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan, K.Assessment Year : 2017-18

For Appellant: Ms. Shree Raksha, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 115BSection 142(1)Section 69ASection 80PSection 80P(2)(a)

collect money in banned currency notes of Rs.500 & 1,000 and the assessee was unable to prove the sources, accordingly. it was treated as unexplained investment u/s. 69A and applied tax rate u/s. 115BBE of the Act. 6. Furthe notice u/s. 133(6) was issued to the Deputy Director

Gobindram Chandramani Vivek, Bangalore vs. Income Tax Officer - Ward 1(1), Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes, in the manner indicated in this order

ITA 656/BANG/2023[2011-12]Status: DisposedITAT Bangalore13 Sept 2024AY 2011-12

Bench: Mrs. Beena Pillai & Shri Ramit Kochar

For Appellant: Sh. Ashok A Kulkarni, AdvocateFor Respondent: Ms. Neha Sahay, JCIT
Section 139Section 139(1)Section 139(4)Section 143(2)Section 143(3)Section 24Section 54Section 54(2)Section 54F

facts stated. 9. The NFAC has not decided the ground of appeal raised before it relating to addition of Rs.1,49,41,000/- as unexplained investment in the property. 10. The Appellant craves for leave to add, to delete from or amend the grounds of appeal.” 3. The brief facts ... third issue relates to the addition made by the AO and as confirmed by ld. CIT(A), on account of allegation of unexplained investment made by the assessee in two residential house properties on 24.05.2010. The ld. Assessing Officer observed that as per AIR information, the assessee has purchased

Manan Jabbar Shaikh, Mumbai vs. ITO Ward-31(2)(3), Mumbai

In the result, the appeal is dismissed

ITA 2338/MUM/2024[2013-14]Status: DisposedITAT Mumbai13 Sept 2024AY 2013-14

Bench: Shri Om Prakash Kant & Ms. Kavitha Rajagopalassessment Year 2013-14 Manan Jabbar Shaikh, Ito, Ward-31(2)(3), Flat No. 803, E.E. Heights, Kautilya Bhavan, Above Delhi Darbar Hotel, Vs. Bkc, Bandra (E), S.V.Road, Jogeshwari West, Mumbai Mumbai Pan : Alvps4316D (Appellant) (Respondent) For Assessee : None For Revenue : Smt. Mahita Nair, Sr.Dr Date Of Hearing : 10-09-2024 Date Of Pronouncement : 13-09-2024

For Appellant: NONEFor Respondent: Smt. Mahita Nair, Sr.DR
Section 250

appellant. 3) That the Ld. Commissioner of Income Tax (Appeals) erred in disregarding the fact that entries cannot only be treated as unexplained investment in bank without considering the nature of the transactions. 4) That the Ld. Commissioner of Income Tax (Appeals) erred levying interest and penalties under various sections

Shivanand Sharanappa Nashi, Vijayapura vs. The ITO, Ward - 3, Vijayapura

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

ITA 1273/BANG/2024[2011-2012]Status: DisposedITAT Bangalore11 Sept 2024AY 2011-2012

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2011-12

For Appellant: Shri Kiran B. Sanmane, CAFor Respondent: Shri V. Parithivel, Jt. CIT(DR)(ITAT), Bengaluru
Section 143(1)Section 143(3)Section 263Section 44ASection 68Section 69A

been carried out towards Current Account. Over and above the cash deposit from the turnover of the assessee is income from other sources as unexplained investment. The definition of section 69A is very much applicable and he referred to page 12 of PB dated 11.3.2019. The assessee has agreed

Ashok Singh Chauhan, Khurja vs. Income Tax Officer Ward 3(1), Bulandshahr

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

ITA 1558/DEL/2024[2009-10]Status: DisposedITAT Delhi11 Sept 2024AY 2009-10

Bench: Shri Kul Bharat[Assessment Year : 2009-10] Ashok Kumar Chauhan, Vs Ito, New Kila Road, Murari Nagar, Ward -3(1), Khurja, Bulandshahr, Bulandshahr. Uttar Pradesh-203131. Pan-Bhfpc1571B Appellant Respondent Appellant By Shri Shailendra Johri, Adv. Respondent By Shri Sanjay Kumar, Sr.Dr Date Of Hearing 22.08.2024 Date Of Pronouncement 11.09.2024

Section 144Section 148Section 250Section 69

agricultural income and out of sale proceeds of his previous sale of the agricultural land. It has been wrongly made addition as an unexplained investment u/s 69 for Rs.3241360.00. 3. That the CIT(A) failed to assess the service of the notices because the notices were not served properly

DCIT, Circle-43(1), Civic Centre vs. Hart Travels and Real Estate Solutions LLP, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 3543/DEL/2023[2018-19]Status: DisposedITAT Delhi11 Sept 2024AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri S.K. Gupta, CAFor Respondent: Shri Choudhary, N.C. Roy, JCIT
Section 115BSection 143(2)Section 271A

under: “1. Ld. CIT(A) has erred in law and facts by deleting the addition of Rs. 2,92,82,500/- on account of unexplained investment despite the fact that the assessee could not bring anything on record to establish that this unexplained investment was from known source of income ... erred in law and facts by accepting the same reasons of unexplained investment which were rejected by the Assessing Officer in absence of documentary evidence. 3. Ld. CIT(A) has erred in law and facts by observing that this unexplained investment was out of preceding and current year withdrawals without

Chandrasekhar Yernena, Visakhapatnam vs. Income Tax Officer, Ward-4(1), Visakhapatnam

In the result, appeal of the assessee is partly allowed as indicated herein above

ITA 125/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam10 Sept 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.125/Viz/2024 (िनधा"रण वष" / Assessment Year : 2016-17) Chandrasekhar Yernena, Vs. Income Tax Officer, 39-31-68, Gandhi Nagar, Ward-4(1), Marripalem, Visakhapatnam. Visakhapatnam-530018, Andhra Pradesh. Pan: Abqpy2029N (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri N.V. Ramana Murthy, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 11/06/2024 घोषणा क" तारीख/Date Of : 10/09/2024 Pronouncement O R D E R

For Appellant: Sri N.V. Ramana Murthy, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 69

perusal of the assessee’s submissions and the evidences placed before him, the Ld. AO made addition of Rs. 15,00,000/- as unexplained investment U/s. 69 of the Act. Further, the Ld. AO estimated the income of the assessee from liquor business ie., @ 5% on the total stock ... taken a very reasonable view while estimating the profit in the absence of books of accounts. Further, with respect to unexplained investment, the Ld. CIT(A)-NFAC observed that the assessee has failed to furnish the proof of his land-holding and agricultural produce apart from some confirmation

Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam vs. Y.Lourdu Reddy, Hyderabad

In the result, cross objections raised by the assessee are dismissed

ITA 328/VIZ/2018[2007-08]Status: DisposedITAT Visakhapatnam09 Sept 2024AY 2007-08

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 132Section 143(2)Section 143(3)Section 153C

Lourdu Reddy Ld.Assessing Officer completed the assessment by making an addition of Rs.2,38,43,000/- and Rs. 1,32,28,500/- as unexplained investments. 4. Being aggrieved by the order of the Ld. Assessing Officer, assessee filed an appeal before Ld. CIT(A). Ld. CIT(A) after considering ... 328/VIZ/2018 C.O. Nos. 59, 60 & 61/VIZ/2019 Joji Reddy Yeruva &Y. Lourdu Reddy assessee’s representative framed the assessment by making the following additions: - i. Unexplained Investment in Highway Paradise Ventures amounting to Rs.391.20 Lakhs; ii. Income From Highway Paradise Venture to the tune of Rs.2

Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam vs. Y.Joji Reddy, Hyderabad

In the result, cross objections raised by the assessee are dismissed

ITA 327/VIZ/2018[2009-10]Status: DisposedITAT Visakhapatnam09 Sept 2024AY 2009-10

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 132Section 143(2)Section 143(3)Section 153C

Lourdu Reddy Ld.Assessing Officer completed the assessment by making an addition of Rs.2,38,43,000/- and Rs. 1,32,28,500/- as unexplained investments. 4. Being aggrieved by the order of the Ld. Assessing Officer, assessee filed an appeal before Ld. CIT(A). Ld. CIT(A) after considering ... 328/VIZ/2018 C.O. Nos. 59, 60 & 61/VIZ/2019 Joji Reddy Yeruva &Y. Lourdu Reddy assessee’s representative framed the assessment by making the following additions: - i. Unexplained Investment in Highway Paradise Ventures amounting to Rs.391.20 Lakhs; ii. Income From Highway Paradise Venture to the tune of Rs.2

Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam vs. Y.Joji Reddy, Hyderabad

In the result, cross objections raised by the assessee are dismissed

ITA 326/VIZ/2018[2008-09]Status: DisposedITAT Visakhapatnam09 Sept 2024AY 2008-09

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 132Section 143(2)Section 143(3)Section 153C

Lourdu Reddy Ld.Assessing Officer completed the assessment by making an addition of Rs.2,38,43,000/- and Rs. 1,32,28,500/- as unexplained investments. 4. Being aggrieved by the order of the Ld. Assessing Officer, assessee filed an appeal before Ld. CIT(A). Ld. CIT(A) after considering ... 328/VIZ/2018 C.O. Nos. 59, 60 & 61/VIZ/2019 Joji Reddy Yeruva &Y. Lourdu Reddy assessee’s representative framed the assessment by making the following additions: - i. Unexplained Investment in Highway Paradise Ventures amounting to Rs.391.20 Lakhs; ii. Income From Highway Paradise Venture to the tune of Rs.2

Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam vs. Y.Joji Reddy, Hyderabad

In the result, cross objections raised by the assessee are dismissed

ITA 325/VIZ/2018[2007-08]Status: DisposedITAT Visakhapatnam09 Sept 2024AY 2007-08

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

Section 132Section 143(2)Section 143(3)Section 153C

Lourdu Reddy Ld.Assessing Officer completed the assessment by making an addition of Rs.2,38,43,000/- and Rs. 1,32,28,500/- as unexplained investments. 4. Being aggrieved by the order of the Ld. Assessing Officer, assessee filed an appeal before Ld. CIT(A). Ld. CIT(A) after considering ... 328/VIZ/2018 C.O. Nos. 59, 60 & 61/VIZ/2019 Joji Reddy Yeruva &Y. Lourdu Reddy assessee’s representative framed the assessment by making the following additions: - i. Unexplained Investment in Highway Paradise Ventures amounting to Rs.391.20 Lakhs; ii. Income From Highway Paradise Venture to the tune of Rs.2

M/S Toplink Commerce Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

ITA 1413/KOL/2023[2012-13]Status: DisposedITAT Kolkata09 Sept 2024AY 2012-13

Bench: Shri Rajpal Yadav & Shri Rakesh Mishraassessment Year: 2012-13

For Appellant: Shri Ankit Jalan, AdvocateFor Respondent: Shri Subhendu Datta, CIT, DR
Section 131Section 133(6)Section 142(1)Section 250Section 68

Noorjahan [1999] 237 ITR 570. However, the facts in the case of P.K. Noorjahan were different as the issue related to unexplained investment in a building u/s 69 of the Act and not unexplained cash credit on account of share capital and share premium received. It is submitted that

Sri Rangarao Nadipally, Karimnagar vs. Deputy Commissioner of Income Tax, Circle - 1, Karimnagar

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

ITA 516/HYD/2024[2014-15]Status: DisposedITAT Hyderabad06 Sept 2024AY 2014-15

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year – 2014-15 Sri Rangarao Nadipally Vs. The Deputy Commissioner Of Income Tax, Karimnagar Circle – 1 Karimnagar Pan : Acbpn3816E (Appellant) (Respondent) Assessee By: Shri M Prudhvi Raj Appeared For Shri D.Sashank, Ld.Ar Revenue By: Shri Srinath Sadanala, Ld.Dr 05.09.2024 Date Of Hearing: Date Of Pronouncement: 06.09.2024

For Appellant: Shri M Prudhvi Raj appeared for Shri D.Sashank, Ld.ARFor Respondent: Shri Srinath Sadanala, Ld.DR

being heard. 4. The NFAC erred in upholding the order passed by the Assessing Officer wherein the opening cash balance has been treated as unexplained investment even though there was closing cash balance available as per earlier return of income filed by the appellant for A.Y.2013-14, which was not disputed

Kondamma Dara, Visakhapatnam vs. Income Tax Officer, Ward-4(6), Visakhapatnam

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

ITA 303/VIZ/2024[2012-13]Status: DisposedITAT Visakhapatnam06 Sept 2024AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकरअपीलसं./I.T.A. No. 303/Viz/2024 (निर्धररवरध/ Assessment Year: 2012-13) Kondamma Dara Income Tax Officer – Ward – 4(6) V. 1-23, Anandapuram Visakhapatnam Visakhapatnam – 531163 Andhra Pradesh [Pan : Bfmpd7127R] (अपीलार्/ Appellant) (प्र्/ Respondent) करद्त्क्पनतनिनरध/ Assessee Represented By : Shri C. Subrahmanyam, Ar : Dr. Aparna Villuri, Sr.Ar र्जसक्पनतनिनरध/ Department Represented By : 04.09.2024 सुिव्ईसम्पहोिेकीनतनि/ Date Of Conclusion Of Hearing घोरर्कीत्रीख/Date Of Pronouncement : 06.09.2024 आदेश/O R D E R Per Shri Duvvuru Rl Reddy: 1. This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), [Hereinafter In Short “Ld.Cit(A)”], National Faceless Appeal Centre (Nfac), Delhi In Din & Order No. Itba/Nfac/S/250/2024-25/1066191061(1) Dated 28.06.2024 Arising Out Of Order Passed Under Section 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short ‘Act’) Dated 31.10.2019 For The A.Y. 2012-13. 2. Briefly Stated Facts Of The Case Are That, Assessee Is An Individual & Has Not Filed Return Of Income For The A.Y. 2012-13. As Per The Information Received

Section 143(2)Section 144Section 147Section 148Section 250Section 250(6)

completed by the Assessing Officer by assessing the income of the assessee at Rs.22,97,365/- after making addition of Rs.22,22,055/- as unexplained investment observing that assessee could not submit explanation for the source of her investment on lands during the F.Y. 2011-12 and treated the same ... unexplained investment and brought to tax. 3. On being aggrieved, assessee preferred an appeal before Ld. CIT(A) but the assessee even after receipt of the hearing notices on various dates did not file any supporting documents on her contentions as per the grounds of appeal raised by the assessee