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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

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 215/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2009-10

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

however assessee did not cooperate and even did not file any reply. Therefore, considering the material on record, the AO made addition as unexplained investment. Even before the learned CIT(A) also the assessee was non cooperative. Number of opportunities were given to the assessee to represent his case, however ... proceeded further with the appeal ex parte and decided the appeal on merits and confirmed the order passed by the AO confirming additions of unexplained investment. Thus, even learned CIT(A) also decided the matter on merits. On going through the orders passed by the AO as well as learned

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 214/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2008-09

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

however assessee did not cooperate and even did not file any reply. Therefore, considering the material on record, the AO made addition as unexplained investment. Even before the learned CIT(A) also the assessee was non cooperative. Number of opportunities were given to the assessee to represent his case, however ... proceeded further with the appeal ex parte and decided the appeal on merits and confirmed the order passed by the AO confirming additions of unexplained investment. Thus, even learned CIT(A) also decided the matter on merits. On going through the orders passed by the AO as well as learned

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 213/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2007-08

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

however assessee did not cooperate and even did not file any reply. Therefore, considering the material on record, the AO made addition as unexplained investment. Even before the learned CIT(A) also the assessee was non cooperative. Number of opportunities were given to the assessee to represent his case, however ... proceeded further with the appeal ex parte and decided the appeal on merits and confirmed the order passed by the AO confirming additions of unexplained investment. Thus, even learned CIT(A) also decided the matter on merits. On going through the orders passed by the AO as well as learned

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 212/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2006-07

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

however assessee did not cooperate and even did not file any reply. Therefore, considering the material on record, the AO made addition as unexplained investment. Even before the learned CIT(A) also the assessee was non cooperative. Number of opportunities were given to the assessee to represent his case, however ... proceeded further with the appeal ex parte and decided the appeal on merits and confirmed the order passed by the AO confirming additions of unexplained investment. Thus, even learned CIT(A) also decided the matter on merits. On going through the orders passed by the AO as well as learned

Shri Ashokji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 211/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2005-06

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

however assessee did not cooperate and even did not file any reply. Therefore, considering the material on record, the AO made addition as unexplained investment. Even before the learned CIT(A) also the assessee was non cooperative. Number of opportunities were given to the assessee to represent his case, however ... proceeded further with the appeal ex parte and decided the appeal on merits and confirmed the order passed by the AO confirming additions of unexplained investment. Thus, even learned CIT(A) also decided the matter on merits. On going through the orders passed by the AO as well as learned

Shri Rohitji Chanduji Thakor, Ahmedabad vs. The ITO, Ward-3(3)(1), Ahmedabad

ITA 210/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

however assessee did not cooperate and even did not file any reply. Therefore, considering the material on record, the AO made addition as unexplained investment. Even before the learned CIT(A) also the assessee was non cooperative. Number of opportunities were given to the assessee to represent his case, however ... proceeded further with the appeal ex parte and decided the appeal on merits and confirmed the order passed by the AO confirming additions of unexplained investment. Thus, even learned CIT(A) also decided the matter on merits. On going through the orders passed by the AO as well as learned

Yash Construction Co., Latur vs. ACIT, Circle 1, Aurangabad

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

ITA 677/PUN/2024[2018-19]Status: DisposedITAT Pune31 Jul 2024AY 2018-19

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sourabh Nayak
Section 115BSection 250Section 69C

business or profession, or capital gains, nor is it income from 'other sources' because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case

Yash Construction Co., Nanded vs. ACIT, Circle, Nanded

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

ITA 676/PUN/2024[2017-18]Status: DisposedITAT Pune31 Jul 2024AY 2017-18

Bench: Shri Rama Kanta Panda & Shri Satbeer Singh Godara

For Appellant: Shri Nikhil PathakFor Respondent: Shri Sourabh Nayak
Section 115BSection 250Section 69C

business or profession, or capital gains, nor is it income from 'other sources' because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income where the nature and source of investment, acquisition or expenditure, as the case

Banda Satyanaraya, Hyderabad vs. Income Tax Officers, Ward-9(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 408/HYD/2021[2012-13]Status: DisposedITAT Hyderabad31 Jul 2024AY 2012-13

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.408/Hyd/2021 (िनधा"रण वष"/Assessment Year: 2012-13) Shri Banda Satyanarayana Vs. Income Tax Officer Hyderabad Ward 9(4) Pan:Acepb2895C Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate T.Chaitanya Kumar, राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 11/07/2024 घोषणा की तारीख/Pronouncement: 31/07/2024 आदेश/Order

For Appellant: Advocate T.Chaitanya KumarFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 143(3)Section 263Section 69

No.1043/2014-15 vide order dated 29.12.2015 dismissed the appeal filed by the assessee and upheld the addition made by the Assessing Officer towards unexplained investment in purchase of property. The assessee preferred an appeal before the ITAT and the ITAT Hyderabad “B” Bench in ITA No.291/Hyd/2016 set aside the issue ... addition towards unexplained investment in purchase of property to the file of the Assessing Officer with a direction to verify the contention of the assessee with regard to the source for investment in purchase of property. Pursuant to the directions of the Tribunal, the Assessing Officer called upon the assessee

Manda Dubey, Hoshangabad vs. Income Tax Officer Itrasi, Itrasi

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

ITA 228/IND/2024[2017-18]Status: DisposedITAT Indore31 Jul 2024AY 2017-18

Bench: Shri Manish Boradmanda Dubey, Ito, Ganeshganj

Section 143Section 143(2)Section 144Section 147Section 148Section 151Section 69A

However all the efforts of Ld. A.O went in vein and ultimately best judgment assessment completed u/s 144 of the Act and addition for unexplained investment u/s 69 of the Act made at Rs.12,60,000/-. Thereafter the assessee challenged the order of the A.O before

Gopalsamy, Chennai vs. CIT(A)-18, Chennai

The appeals stands allowed in terms of our above order

ITA 1384/CHNY/2023[2015-16]Status: DisposedITAT Chennai31 Jul 2024AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.1384/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.1385/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) & 3. आयकरअपील सं./ Ita No.1386/Chny/2023 (िनधा"रणवष" / Assessment Year: 2019-20) Shri Gopalsamy Vs. Acit No.3B, 3Rd Floor New No.27 Dc/Ac Central Cir 1(2) East Street, Krishna Apartments, Chennai Raghava Reddy Colony, Ashok Nagar, Chennai 600 083. [Pan: Bjtpg 4193H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri R. Subramanian, C.A., ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit. सुनवाई क" तार"ख/Date Of Hearing : 21.05.2024 घोषणा क" तार"ख /Date Of Pronouncement : 31.07.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri R. Subramanian, C.AFor Respondent: Shri Nilay Baran Som, IRS, CIT
Section 153CSection 253

undisclosed income. Similarly addition of Rs.23.50 Lacs was made in AY 2017-18. 4.5 In AY 2017-18, Ld. AO made addition of unexplained investment u/s 69 for Rs.107.40 Lacs with respect to investment in immoveable properties. The same was subjected to the provisions of Sec.115BBE ... under: ‘’Investment of Rs. 1,07,40,985/- pertaining to Flat at No.3b, 27/14, Ragahava Reddy colony, Ashok Nagar, Chennai is treated as unexplained investment: In this connection the Appellant wish to inform to this authority that the Appellant has purchased the UDS land in Ashok Nagar for a Total

Samarjit Singh Chabra, Chennai vs. ITO Non Corporate Ward 14(1), Chennai

In the result, all the appeals filed by the assessee in ITA No

ITA 1646/CHNY/2018[2008-09]Status: DisposedITAT Chennai31 Jul 2024AY 2008-09

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

assessee challenging the action of the ld. CIT(A) in sustaining the investment to an extent of ₹.17,45,000/- on account of unexplained investment at Madikapakkam flat. 104. We note that the assessee claimed purchase of flat at Ram Nagar, Madipakkam for a consideration ... corroborative evidence towards cash payment of ₹.17,45,000/-, the Assessing Officer added the same to the total income of the assessee as unexplained investment under section 69 of the Act. 61 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 105. Before the ld. CIT(A), it was contended that when

Samarjit Singh Chabra, Chennai vs. ITO Non Corporate Ward 14(1), Chennai

In the result, all the appeals filed by the assessee in ITA No

ITA 1625/CHNY/2018[2010-11]Status: DisposedITAT Chennai31 Jul 2024AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

assessee challenging the action of the ld. CIT(A) in sustaining the investment to an extent of ₹.17,45,000/- on account of unexplained investment at Madikapakkam flat. 104. We note that the assessee claimed purchase of flat at Ram Nagar, Madipakkam for a consideration ... corroborative evidence towards cash payment of ₹.17,45,000/-, the Assessing Officer added the same to the total income of the assessee as unexplained investment under section 69 of the Act. 61 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 105. Before the ld. CIT(A), it was contended that when

Samarjit Singh Chabra, Chennai vs. ITO Non Corporate Ward 14(1), Chennai

In the result, all the appeals filed by the assessee in ITA No

ITA 1624/CHNY/2018[2009-10]Status: DisposedITAT Chennai31 Jul 2024AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

assessee challenging the action of the ld. CIT(A) in sustaining the investment to an extent of ₹.17,45,000/- on account of unexplained investment at Madikapakkam flat. 104. We note that the assessee claimed purchase of flat at Ram Nagar, Madipakkam for a consideration ... corroborative evidence towards cash payment of ₹.17,45,000/-, the Assessing Officer added the same to the total income of the assessee as unexplained investment under section 69 of the Act. 61 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 105. Before the ld. CIT(A), it was contended that when

Samarjit Singh Chabra, Chennai vs. ITO Non Corporate Ward 14(1), Chennai

In the result, all the appeals filed by the assessee in ITA No

ITA 1623/CHNY/2018[2007-08]Status: DisposedITAT Chennai31 Jul 2024AY 2007-08

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT
Section 142(1)

assessee challenging the action of the ld. CIT(A) in sustaining the investment to an extent of ₹.17,45,000/- on account of unexplained investment at Madikapakkam flat. 104. We note that the assessee claimed purchase of flat at Ram Nagar, Madipakkam for a consideration ... corroborative evidence towards cash payment of ₹.17,45,000/-, the Assessing Officer added the same to the total income of the assessee as unexplained investment under section 69 of the Act. 61 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 105. Before the ld. CIT(A), it was contended that when

Silver Wings Life Spaces, Kota vs. DCIT Circle-1 Kota, Kota

In the result, the appeal of the assessee is allowed

ITA 511/JPR/2024[2017-18]Status: DisposedITAT Jaipur31 Jul 2024AY 2017-18

Bench: Learned Cit(A), Which Appeal Was Filed By The Assessee

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. A. S. Nehra(Addl. CIT)
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

facts of the case in treating the surrendered income on account of sundry debtors and excess cash fond as income undisclosed or unexplained investment or money u/s 69 & 69A in place of “business income” as the same was generated from business or was of business income and also erred ... return of income, and paid taxes at normal rate. 3.4 Ld. AO noted that as the assessee had disclosed the income as unexplained investment in form of debtors, same was covered by section 69 of the IT Act &the excess cash was covered

Madhuri Bhattacharya, Bangalore vs. Assistant Commissioner of Income Tax, Circle-2(3)(1), Bangalore

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

ITA 630/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubeymadhuri Bhattacharya Acit, Circle 2(3)(1) No. 363, 11Th Cross Bmtc Building 4Th Main Road, 2Nd Block Vs. Koramangala R.T. Nagar, Bangalore 560032 Bangaore 560095 Pan – Ahepb0337N (Appellant) (Respondent) Assessee By: Shri Deepak Chopra, Ca Revenue By: Shri V. Parithivel, Jcit-Dr Date Of Hearing: 13.05.2024 Date Of Pronouncement: 31.07.2024 O R D E R Per: Keshav Dubey, J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 27.02.2024 Vide Din & Order No. Itba/Nfac/S/250/2003-24/1061593922(1) Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) In Respect Of Assessment Year (Ay) 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Orders Of Lower Authorities Are Bad In Law & Liable To Be Quashed For: A) Non-Consideration Of Material On Record & Submissions Of The Appellant B) Want Of Application Of Principles Of Natural Justice. Without Prejudice: 2. The Learned Assessing Officer Has Erred In Making An Addition Of Rs. 1,93,00,000 As Unexplained Investment & 36,00,000 As Expenditure Not Related To The Profession Without Issuing A Show Cause Notice As Mandated

For Appellant: Shri Deepak Chopra, CAFor Respondent: Shri V. Parithivel, JCIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 234BSection 234CSection 250

principles of natural justice. Without prejudice: 2. The learned assessing officer has erred in making an addition of Rs. 1,93,00,000 as unexplained investment and 36,00,000 as expenditure not related to the profession without issuing a show cause notice as mandated 2 Madhuri Bhattacharya ... required to be deleted in toto. 3.1 The learned assessing officer has erred in taxing a sum of Rs.1,93,00,000/- as unexplained investments in the hands of the appellant. The learned CIT(A) has erred in confirming the same. On the facts of the appellant's case

Makam Prasanna, Nrc Buidling Mg Road vs. Income Tax Officer, Ward-, Chikaballapur

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

ITA 1083/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Jul 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 115BSection 133(6)Section 69A

made by the AO and the same has been confirmed by the CIT(A), in respect of cash deposits in the Bank accounts, as unexplained investments u/s. 69A of the Act, is not sustainable and liable to be deleted.” 2. Briefly stated the facts of the case are that assessee

Jatin Narendra Joshi, Mumbai vs. ITO 25(1)(1), Mumbai

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

ITA 2245/MUM/2024[2015-2016]Status: DisposedITAT Mumbai31 Jul 2024AY 2015-2016

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh () Assessment Year: 2015-16 Jatin Narendra Joshi, Ito 25(1)(1), 401, 4Th Floor, Embassy Building, Kautilya Bhavan, Vs. Bhakti Park, Wadala Link Road, Bandra Kurla Complex, Near Imax Big Cinema, Mumbai. Wadala East, Mumbai-400037. Pan No. Aabpj 8856 A Appellant Respondent

For Appellant: Ms. Rajeshwari Menon, Sr. DRFor Respondent: Mr. Mehul Shah
Section 69

Income Tax Act, 1961 alleging unexplained of the Income Tax Act, 1961 alleging unexplained of the Income Tax Act, 1961 alleging unexplained investment thereby treating that, the source of these funds investment thereby treating that, the source of these funds investment thereby treating that, the source of these funds ... addition of Rs. 1. In ground no.1, assessee objects to addition of Rs. 9926707 u/s 69 as unexplained in 9926707 u/s 69 as unexplained investment being the vestment being the amount invested for purchase of flats. The assessee could amount invested for purchase of flats. The assessee could amount invested

The DCIT, Central Circle-1(1), Ahmedabad vs. Shri Umang H. Thakkar, Ahmedabad

In the result, the appeal filed by the assessee bearing ITA No

ITA 2548/AHD/2008[2005-06]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2005-06

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Bandish Soparkar, AR &For Respondent: Shri Akhilendra Pratap Yadav, CIT-DR
Section 132Section 143(2)Section 250(6)

cash by the assessee for acquiring the jewellery. 7.3 The Revenue is in appeal before us against the deletion of addition made of unexplained investment in jewellery of 496 gms found at the Assessee-Shri Umang Hiralal Thakkar-Cross Appeals AY : 2005-06 residence of the assessee which was attributed ... reads as under:- “The CIT(A) has erred in law and on facts in deleting the addition of Rs.84.50 lacs made on account of unexplained investment in purchase of land from Shri Vikas Shah and Others without considering the entries recorded on seized document as well as the statement