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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

Christian Multipurpose Co-Operative Society Limited, Chickmagalur vs. Income Tax Officer, Ward-1, Chikmagalur

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

ITA 551/BANG/2024[2017-18]Status: DisposedITAT Bangalore25 Jun 2024AY 2017-18

Bench: Shri George George Kr Assessment Year : 2017-18 M/S. Christian Multipurpose Co-Operative Vs. Ito, Society Ltd., Ward – 1, Mathias Tower I G Road, Chikmagalur. Chikmagalur – 577 101. Pan : Aabac 7847 F Appellant Respondent Assessee By : Shri. Varun Bhat, Ca Revenue By : Shri. Ganesh R Gale, Standing Counsel For Department. Date Of Hearing : 24.06.2024 Date Of Pronouncement : 25.06.2024

For Appellant: Shri. Varun Bhat, CAFor Respondent: Shri. Ganesh R Gale, Standing Counsel for Department
Section 115BSection 142(1)Section 143(2)Section 144Section 250Section 69

relevant finding of the AO with regard to addition made under section 69 of the Act reads as follows: “1. Unexplained investment : On perusal of the information available on records, it is seen that the assesee has made cash deposits aggregating to Rs. 26,26.300/- in CDCC Bank, Chickamagaluru ... absence of any explanation from the assessee the cash deposits made during the demonetisation period amounting to Rs. 26,26,300/- is treated as unexplained investment of the assessee brought to tax u/s. 69 of the Income Tax Act. 1961 under the head Income from Other Sources and taxable under

Income Tax Officer, Mumbai vs. Mukesh Pruthviram Chouhan, Mumbai

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

ITA 3580/MUM/2023[2014-15]Status: DisposedITAT Mumbai25 Jun 2024AY 2014-15

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriincome Tax Officer Vs. Mukesh Pruthviram Room No. 713, Kautilya Chouhan Bhavan, Income Tax Office, 305, Dhobhighat, Suratbai Bandra Kurla Complex, Chawl, Chincholi Phatak, Bandra (E), Malad(E), Maharashtra-400051 Maharashtra-400097 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aeupc2821B Appellant .. Respondent

For Appellant: NoneFor Respondent: Shri Nagnath Pasale
Section 131Section 250Section 69Section 69A

also for the same assessment year.” b. In view of the above facts, the AO treated the sum of Rs. 42,47,000/- as unexplained investment and added the same u/s 69 of the Act. However, while computing the income, relevant section has been erroneously mentioned as 69A instead

Sher Singh, Palampur vs. Income Tax Officer, Palampur

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

ITA 664/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh24 Jun 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Ashwani Kumar, C.AFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 131Section 142(1)Section 143(2)Section 148Section 250Section 253Section 272A(1)(d)

also cited some case laws and stated that cash sales if deposited in bank account can never be treated as unexplained income or unexplained investment as per section 68 and 69A when there are no defects found in the books of accounts.4.2 Assessee reply has been considered but not found

Amish Umesh Jani, Thane, Maharashtra vs. Income Tax Officer Ward 4(2)(5), Ahmedabad, Gujarat

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

ITA 864/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad24 Jun 2024AY 2010-11

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: Shri Malay Kalavadia, A.RFor Respondent: Shri M. Anand Kumar, Sr. D.R
Section 142(1)Section 144Section 148Section 271

r.w.s 147, wherein addition of Rs. 10,00,000/- was made by the AO as income of the assessee on account of unexplained investment made by the assessee in the purchase of bonds of NHAI on 24-09-2009 of Rs. 10,00,000/-. Second addition was made ... income from house property, and there is no dispute as to the said income. The only dispute is w.r.t. unexplained investment of Rs. 10,00,000/- in NHAI Bonds made on 24.09.2009, which has been accepted by AO in remand report as being explained being made out of the sale

Sapphire Trade Associates (P) Ltd., Kolkata vs. ITO, Ward-8(2), Kolkata.

In the result, the appeal of the assessee is allowed

ITA 709/KOL/2023[2014-15]Status: DisposedITAT Kolkata24 Jun 2024AY 2014-15

Bench: Shri Sanjay Garg&Shri Rajesh Kumar]

Section 131Section 133(6)Section 143(1)Section 143(3)Section 68

ascertained on the basis of surrounding circumstances and thus treated the amount of share capital/share premium of Rs. 2,97,61,000/- as unexplained investment u/s 68 of the Act and added the same to the income of the assessee in the assessment framed

DCIT (Central), Bhopal vs. Shailendra Sharma, Bhopal

In the result the appeals of the assessee for the Assessment

ITA 305/IND/2023[2015-16]Status: DisposedITAT Indore24 Jun 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 142(1)Section 153A

which was subsequently transferred to the parties as discussed above through the mode of banking channel. Such amount of cash deposit was treated as unexplained investment in the hands of the assessee under the provisions of section of the Act and therefore the same was added to the total income

Malaya Radha Krishna Akashdeep, Bangalore vs. Income-Tax Officer, Ward-1, Chikaballapur

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

ITA 732/BANG/2024[2017-18]Status: DisposedITAT Bangalore24 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year: 2017-18

For Appellant: Sri Rajeev C. Nulvi, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 115BSection 131Section 133(6)Section 250Section 69A

case. 2. On the fact and circumstances of the case, the Assessing Officer erred in making the addition of Rs.85,00,000/- as unexplained investment u/s 69A for cash deposits made during the period other than demonetization period, as the same cash deposits were not belonging to the Appellant ... that deposit for which there was no response. Hence, the ld. AO made addition of Rs.85 lakhs u/s 69A of the Act as unexplained investment on account of cash deposited to assessee’s bank account. Against this assessee carried appeal before NFAC belatedly by 55 days. The Malaya Radha Krishna

Rakesh Chandranath Sharma, Mumbai vs. ITO-42(3)(2), Mumbai

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

ITA 4124/MUM/2023[2015-16]Status: HeardITAT Mumbai24 Jun 2024AY 2015-16

Bench: Ms Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am Rakesh Chandranath Sharma Ito-42(3)(2) 4, Adhikari Bhavan, Kautilya Bhavan, G Block, Near Hotel Classic, Bkc Bandra Kurla Complex, Behind Jain Sweets, Old Nagardas Vs. Bandra (E), Mumbai-400 051 Road, Andheri(E), Mumbai-400 069

For Appellant: Shri Bhupendra ShahFor Respondent: Smt. Mahita Nair
Section 143(1)Section 143(3)Section 250Section 271(1)Section 68

determining the total income at Rs.75,46,400/- after making an addition of RS.64,84,598/-, relating to sale proceeds of shares as unexplained investment and Rs.1,94,538/- being the addition on account of commission for the said transaction as unexplained expenditure. 4. The assessee was in appeal before

Balaka Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, appeals of the assessee in ITA No

ITA 161/KOL/2024[2008-09]Status: DisposedITAT Kolkata21 Jun 2024AY 2008-09

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 160 & 161/Kol/2024 Assessment Year: 2008-09 Balaka Vinimay Pvt. Ltd. Income Tax Officer, Ward – 2(1), 9/12, Lal Bazar Street Vs Kolkata Kolkata - 700001 [Pan : Aadcb2610B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A.K. Tibrewal, A/R & Saurav Gupta, A/R Revenue By : Shri Abhijit Kundu, Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Instant Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi, (Hereinafter The “Ld. Cit(A)”). Ita No. 160/Kol/2024 Is Against The Order Of The Ld. Cit(A) Dt. 29/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) Arising Out Of The Penalty Order Passed By The Ld. Assessing Officer U/S 271(1)(C) Of The Act & Ita No. 161/Kol/2023, Is Against The Order Of The Ld. Cit(A) Dt. 28/11/2023, Arising Out Of The Order Of The Ld. Assessing Officer Passed U/S 143(3) R.W.S. 254 Of The Act, For Assessment Year 2008-09. 2. Though The Assessee Has Raised Various Grounds In Both These Appeals, But The Effective Issue Raised In Ita No. 161/Kol/2024 Is Against The Addition Made U/S 68 Of The Act For Unexplained Share Capital Confirmed By The Ld. Cit(A) & In Ita No. 160/Kol/2024 Is Against The Levy Of Penalty U/S 271(1)(C) Of The Act On The Addition Made

For Appellant: Shri A.K. Tibrewal, A/R and Saurav Gupta, A/RFor Respondent: Shri Abhijit Kundu, CIT, Sr. D/R
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 271(1)(c)Section 68

proper course would ^have been to make assessments in the cases of those creditors by treating the cash deposits in their bank accounts as unexplained investments of those creditors under section 69.” 15. Our view is supported by Tradelink Carrying (P.) Ltd. vs ITO pronounced on 20.12.2019 reported

Balaka Vinimay Pvt. Ltd., Kolkata vs. ITO, Ward-2(1), Kolkata

In the result, appeals of the assessee in ITA No

ITA 160/KOL/2024[2008-09]Status: DisposedITAT Kolkata21 Jun 2024AY 2008-09

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 160 & 161/Kol/2024 Assessment Year: 2008-09 Balaka Vinimay Pvt. Ltd. Income Tax Officer, Ward – 2(1), 9/12, Lal Bazar Street Vs Kolkata Kolkata - 700001 [Pan : Aadcb2610B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A.K. Tibrewal, A/R & Saurav Gupta, A/R Revenue By : Shri Abhijit Kundu, Cit, Sr. D/R सुनवाई क" तारीख/Date Of Hearing : 09/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 21/06/2024 आदेश/O R D E R Per Dr. Manish Borad: The Instant Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre, Delhi, (Hereinafter The “Ld. Cit(A)”). Ita No. 160/Kol/2024 Is Against The Order Of The Ld. Cit(A) Dt. 29/11/2023, Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter ‘The Act’) Arising Out Of The Penalty Order Passed By The Ld. Assessing Officer U/S 271(1)(C) Of The Act & Ita No. 161/Kol/2023, Is Against The Order Of The Ld. Cit(A) Dt. 28/11/2023, Arising Out Of The Order Of The Ld. Assessing Officer Passed U/S 143(3) R.W.S. 254 Of The Act, For Assessment Year 2008-09. 2. Though The Assessee Has Raised Various Grounds In Both These Appeals, But The Effective Issue Raised In Ita No. 161/Kol/2024 Is Against The Addition Made U/S 68 Of The Act For Unexplained Share Capital Confirmed By The Ld. Cit(A) & In Ita No. 160/Kol/2024 Is Against The Levy Of Penalty U/S 271(1)(C) Of The Act On The Addition Made

For Appellant: Shri A.K. Tibrewal, A/R and Saurav Gupta, A/RFor Respondent: Shri Abhijit Kundu, CIT, Sr. D/R
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 263Section 271(1)(c)Section 68

proper course would ^have been to make assessments in the cases of those creditors by treating the cash deposits in their bank accounts as unexplained investments of those creditors under section 69.” 15. Our view is supported by Tradelink Carrying (P.) Ltd. vs ITO pronounced on 20.12.2019 reported

Vivek Ramsing Padvi, Mumbai vs. Income Tax Officer-Ward 29(3)(5), Mumbai

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

ITA 357/MUM/2024[2009-10]Status: DisposedITAT Mumbai21 Jun 2024AY 2009-10

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Shahank MehtaFor Respondent: Ms. Rajeshwari Menon
Section 143(1)Section 144Section 147Section 148Section 151Section 250Section 69

total income at Rs.2,54,31,110/- after making an addition of Rs.2,53,26,125/- u/s. 69 of the Act on account of unexplained investment. 5. The assessee was in appeal before the first appellate authority, challenging the assessment order and the ld. CIT(A) vide an ex parte

Vivek Ramsing Padvi, Mumbai vs. Income Tax Officer, Ward 29(3)(5), Mumbai

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

ITA 356/MUM/2024[2008-09]Status: DisposedITAT Mumbai21 Jun 2024AY 2008-09

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Shahank MehtaFor Respondent: Ms. Rajeshwari Menon
Section 143(1)Section 144Section 147Section 148Section 151Section 250Section 69

total income at Rs.2,54,31,110/- after making an addition of Rs.2,53,26,125/- u/s. 69 of the Act on account of unexplained investment. 5. The assessee was in appeal before the first appellate authority, challenging the assessment order and the ld. CIT(A) vide an ex parte

Vishwesh Venkatraman, Norway and Uk vs. ITO (It) 4(3)(1), Air India Building Mumbai

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

ITA 1515/MUM/2024[2017-2018]Status: DisposedITAT Mumbai21 Jun 2024AY 2017-2018

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: S/Shri Harshavardhana Datar / Amit NegandhiFor Respondent: Shri Anil Sant, Addl.CIT-DR
Section 144C(13)Section 147Section 151Section 234CSection 3Section 69

therefore, you are required to show cause as to why this amount should not be added to your total income on account of unexplained investments u/s.69 along with documentary evidences clearly explaining the said investment.” 8. The assessee reiterated what he has stated earlier. Simultaneously, the assessee sought directions from

Pramod Kumar Singh, Kalyan, Thane vs. Commissioner of Income Tax (Appeals), Thane, Maharashtra

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

ITA 4759/MUM/2023[2014-15]Status: DisposedITAT Mumbai21 Jun 2024AY 2014-15

Bench: Shri Amarjit Singh & Shri Rahul Chaudhary, Pramod Kumar Singh, Vs. Ito Ward 17(2)(1) A Wing Room No. 2, Mumbai Shalaka Chsl, Manpada Road, Gandhinagar, Dombivali East, Kalyan – 421204 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Atzps5807M Appellant .. Respondent

For Appellant: Rahul BombaleFor Respondent: H.M. Bhatt
Section 133(6)Section 144BSection 147Section 148Section 194CSection 250Section 68Section 69

facts and in the circumstances of the case and law, the Ld. Commissioner of Income Tax (Appeals) erred in adding ADDITION TOWARDS UNEXPLAINED INVESTMENT AS PER SECTION 69 OF THE IT ACT 1961. The Assessee had purchased under-construction property at (Patharli Panvel) having project address Flat No 702, building ... actual receipt of Rs.22,85,403/- shown by the assessee. The AO has also made addition of Rs.20,69,925/- as unexplained investment in the immovable property u/s 69 of the Act. During the course of appellate proceedings before the ld. CIT(A) the assessee had not made compliance since

Jasudben Navinchandra Modi, Ahmedabad vs. The ITO, Ward-1(2)(2) Present Jurisdiction the ITO, Ward-1(2)(3), Ahmedabad

ITA 395/AHD/2024[2014-15]Status: HeardITAT Ahmedabad20 Jun 2024AY 2014-15

Bench: The Income Tax Appellate Tribunal, Ahmedabad Benches, Ahmedabad Which Has Arisen From The Appellate Order Dated 05.04.2022

For Appellant: NoneFor Respondent: Shri M. Anand Kumar, Sr. D.R
Section 139Section 142(1)Section 144Section 148Section 69

Rs.26,00,000/- in Bonds during the year under consideration should not be assessed as your total income u/s 69 of the Act as unexplained investment. Further, you are hereby show caused to explain as to why the interest income of Rs. 37,430/- earned during the year under consideration ... income. The Assessing Officer made the addition of income to the extent of Rs. 26 lakhs in the hands of the assessee towards unexplained investment in acquisition of debentures/bonds of NHAI/REC during the year under consideration u/s. 69 of the Act. Further, addition of interest income

Rajesh Kumar Jaiswal, Shrawasti vs. ITO, WD 6(4), Jaipur

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

ITA 306/JPR/2022[2017-18]Status: DisposedITAT Jaipur20 Jun 2024AY 2017-18

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

For Appellant: Shri Rajesh Kumar Jaiswal (Self)For Respondent: Shri A.S. Nehra (Addl.CIT)
Section 127(2)Section 143(2)Section 143(3)Section 69Section 69A

facts in failing to consider the requisite documentary evidence furnished by the appellant and arbitrarily confirming the addition of Rs.2,72,65,000/- as unexplained investment u/s 69A of the I.T. Act, 1961, on the basis of presumption, surmises and conjectures. 3. That the appellant craves permission for amending ... cash withdrawals Rs. 2,72,65,000) was not found to be satisfactory/acceptable and arbitrarily added the sum of Rs.2,72,65,000/- as unexplained investment under section 69A of the IT Act, 1961. The assessment has arbitrarily been made on total income

Arumuga Nadar Soundararajan Rep by L/H Sudarsan, Chennai vs. ITO, Ncw 19(4), Chennai

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

ITA 446/CHNY/2024[2017-18]Status: DisposedITAT Chennai19 Jun 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.446/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-18) Arumuga Nadar Soundararajan, Vs. The Income Tax Officer, Rep By L/H. Sri Sudharsan, Non Corporate Ward 19(4) No.16, Lakeview Road Extn, Chennai West Mambalam, Chennai 600 033. [Pan: Aalps 5134J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Anand Babunath, Ca ""यथ" क" ओर से /Respondent By : Shri. R. Mukundan, Irs, Jcit सुनवाई क" तार"ख/Date Of Hearing : 13.06.2024 घोषणा क" तार"ख /Date Of Pronouncement : 19.06.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. Anand Babunath, CAFor Respondent: Shri. R. Mukundan, IRS, JCIT
Section 115BSection 133ASection 142(1)Section 143(1)Section 143(3)Section 234Section 44ASection 69

since the case of the Appellant is covered under Tax Audit u/s. 44AB of the IT Act, 1961. The Ld. AO had estimated the unexplained investment at Rs. 35,00,000/- which have been disclosed as income in the Profit & Loss Account and does not warrant a separate addition under ... Canara Bank and ICICI Bank totalling Rs.64,53,000/-. The AO in its assessment order dated 19.12.2019 made an addition on account of unexplained investment of Rs.35,00,000/- u/s 69 r.w.s.115BBE of the Act. Ld.CIT(A) has dismissed the appeal and upheld the order of AO. Hence, assessee

Nagendran Sankara Narayan, Chennai vs. ITO, Ncw 10(3), Chennai

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

ITA 1414/CHNY/2024[2017-18]Status: DisposedITAT Chennai19 Jun 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1414/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-18) & Sp No.26/Chny/2024 (In Ita No.1414/Chny/2024)

For Respondent: Shri. R. Mukundan, IRS, JCIT
Section 115BSection 143(3)Section 69

therefore, AO has given benefit of the same while making assessment and balance of Rs.6,19,081/-was treated as unexplained investment. Feeling aggrieved with the order of Assessing Officer assessee filed an appeal before the Ld.CIT(A). After adjudication, Ld.CIT(A) has dismissed the ground of the assessee ... upheld the addition made by AO on account of unexplained investment of Rs. 6,19,081/-. Hence, assessee is further in appeal before us. 4. Ld.Counsel, before us prayed that in the given facts a reasonable estimate can be made restricting addition to 50% of the total addition which

Muvin Khan, Jhajhar vs. Income Tax Officer, Ward-3(2) Bulandshahr, Bulandshahr

The appeal of the assessee is allowed for statistical purposes

ITA 1201/DEL/2024[2012-13]Status: DisposedITAT Delhi19 Jun 2024AY 2012-13

Bench: Shri Pradip Kumar Kediaassessment Year 2012-13

For Respondent: Shri Om Prakash, Sr.DR
Section 144Section 147Section 250Section 69

Counsel submitted that the source of cash is corroborated by documentary evidences and therefore, there is no rationale in making such additions as unexplained investment in the hands of the assessee. Adverting further, the ld. Counsel submitted that the AO has resorted to best judgment assessment under Section

ACIT Central Circle, Meerut vs. Dr. Leena Chaudhary, Meerut

In the result, the appeal of the revenue is dismissed

ITA 1350/DEL/2022[2018-19]Status: DisposedITAT Delhi19 Jun 2024AY 2018-19

Bench: Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2018-19 Acit Vs. Dr. Leena Chaudhary Central Circle A-43/A, Defence Colony, Meerut Meerut -250001 Pan No.Acrpp0653M (Appellant) (Respondent) Appellant By Sh. Subhra Jyoti Chakraborty, Cit Dr Respondent By Sh. P.S. Kashyap, Ca Date Of Hearing: 16/05/2024 Date Of Pronouncement: 19/06/2024 Order

Section 132Section 133ASection 142(1)Section 143(2)Section 153ASection 69BSection 69C

been shown by the assessee. The AO also made the addition of Rs.37,03,300/- under Section 69B of the Act on account of unexplained investment. 3. Aggrieved by the order passed by the AO the assessee filed an appeal before the CIT(A). The Ld. CIT(A) partly allowed ... erred in law and on facts in deleting the additions of Rs. 37,03,000/- made by the assessing officer on account of unexplained investment u/s 69B of the I.T. Act by observing that the valuation of the property done by the DVO and estimated fair market value cannot