“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

Prashant Vithoba Navale, Solapur vs. Deputy Commissioner of Income-Tax, Central Circle -2(2), Pune

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

ITA 323/PUN/2019[2012-13]Status: DisposedITAT Pune27 May 2024AY 2012-13

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2012-13

For Appellant: Shri Suhas BoraFor Respondent: Shri Sourabh Nayak, Addl.CIT

Section 132Section 143(2)Section 147Section 148

cash deposits in bank account as unexplained cash credit. 16. As mentioned earlier, the Assessing Officer made the addition of Rs.53,31,980/- as unexplained investment being the cash deposits in various bank accounts on the ground that the assessee could not explain the source of such deposits

Naveen Kumar Bitla, Warangal vs. Assistant Commissioner of Income Tax Circle-7(1), Hyderabad

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

ITA 590/HYD/2023[2017-18]Status: DisposedITAT Hyderabad27 May 2024AY 2017-18

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.590/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Naveen Kumar Bitla Vs. Acit Warangal Circle 7(1) Pan:Atfpb0191D Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S Sandhya राज" व "ारा/Revenue By:: Smt. Helen Ruby Jesindha, Dr सुनवाई की तारीख/Date Of Hearing: 27/05/2024 घोषणा की तारीख/Pronouncement: 27/05/2024 आदेश/Order

For Appellant: Advocate S SandhyaFor Respondent: : Smt. Helen Ruby Jesindha, DR

Section 69

cannot accept specified bank notes after 8.11.2016 and thus rejected the explanation of the assessee and made the addition of Rs.9,69,591/- as unexplained investment taxable u/s 69 of the I.T. Act, 1961. Page 3 of 6 ITA No 590 of 2023 Naveen Kumar Bitla Warangal 6. The assessee

ACIT, Central Circle-3(3), Hyderabad vs. Venkata Praneeth Developers Private Limited, Hyderabad

The appeal of the assessee is dismissed

ITA 339/HYD/2022[2020-21]Status: DisposedITAT Hyderabad27 May 2024AY 2020-21

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No. 279/Hyd/2022 (िनधा"रण वष" / Assessment Year: 2020-21) Venkata Praneeth Vs. Acit Developers (P) Ltd, Central Circle 3(3) Hyderabad Hyderabad Pan:Aaccv4975A (Appellant) (Respondent) आ.अपी.सं /Ita No. 339/Hyd/2022 (िनधा"रण वष" / Assessment Year: 2020-21) Acit Vs. Venkata Praneeth Central Circle 3(3) Developers (P) Ltd, Hyderabad Hyderabad Pan:Aaccv4975A (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ravi Bharadwaj, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Dr सुनवाई की तारीख/Date Of Hearing: 06/05/2024 घोषणा की तारीख/Pronouncement: 27/05/2024

For Appellant: Shri Ravi Bharadwaj, CAFor Respondent: : Shri Kumar Pranav, DR

Section 132Section 139(1)Section 143(2)Section 143(3)

have discussed the statement of the assessee and thereafter has recorded that the amount of Rs.1.00 crore is required to be treated as unexplained investment as cash loan to Ms. M. Padmavathi. The contention of the assessee before us is that the Accountant of the assessee has not updated

Venkata Praneeth Developers Private Limited, Hyderabad vs. ACIT Central Circle-3(3), Hyderabad

The appeal of the assessee is dismissed

ITA 279/HYD/2022[2020-21]Status: DisposedITAT Hyderabad27 May 2024AY 2020-21

For Appellant: Shri Ravi Bharadwaj, CAFor Respondent: : Shri Kumar Pranav, DR

Section 132Section 139(1)Section 143(2)Section 143(3)

Manganga Sahakari Patsanstha Limited, Mumbai vs. Income Tax Officer, National E-Assessment Centre

ITA 1843/MUM/2024[2018-19]Status: HeardITAT Mumbai27 May 2024AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri S.V. Apate, Adv

Section 142(1)Section 143(2)

given to the assessee for hearing and therefore, the order is bad in law. Further assessee challenged that with respect to the addition of unexplained investment there is a new addition of ₹12,287/- new members and assessee has received 47 crores of as new deposits and therefore, the addition ... however the assessee has stated that there is a failure to give appropriate opportunity of hearing to the assessee and further the additions of unexplained investment is uncalled for in view of the sources of fund of ₹46.61 from 12,827 new members. Further deduction claimed under Section

M/S Varun Resources Limited, Mumbai vs. Commissioner of Income Tax (Appeal)-Circle 5(3)(1), Mumbai

In the result, the appeal is partially allowed

ITA 4518/MUM/2023[2017-18]Status: DisposedITAT Mumbai27 May 2024AY 2017-18

Bench: the NCLT during the course of assessment proceedings. Notice was issued to the liquidator Mr. Sanjeev Maheshwari but for no avail. It was learnt that assessee under reported income as Rs 34,06,89,638/- as per order dated 3

Section 115JSection 143(2)Section 143(3)Section 147Section 270Section 270ASection 270A(2)Section 274Section 69A

levying penalty on the addition of Rs. 7,00,00,000/- towards the amount of FD made during the year u/s 69A as unexplained investments. B. The learned AU erred in not appreciating the fact that: i. The existence of the FD was explained to the AU with books ... prays the penalty levied on addition of Rs. 7,00,00,000/- towards the amount of FD made during the year u/s 69A as unexplained investments may please be deleted. GROUND 4 (without prejudice to ground 1) A. On the facts and circumstances of the case, the Assessment Unit

Suraj Popatrao Wagh, Mumbai vs. Income Tax Office-3(4), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 4157/MUM/2023[2017-18]Status: DisposedITAT Mumbai24 May 2024AY 2017-18

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Ms. Naina Chaurasia, CAFor Respondent: 23.04.2024

Section 142(1)Section 144Section 250Section 69Section 69A

erred in law and on facts in sustaining/ confirming addition of Rs.8,19,468/- being credits appearing in the bank account as unexplained investment as per the provisions of section 69 of the Income Tax Act, 1961. 3. The learned Commissionaire of Income Tax (A) erred

Anju Singh, Noida vs. Income Tax Officer, Noida

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

ITA 3498/DEL/2023[2010-11]Status: DisposedITAT Delhi24 May 2024AY 2010-11

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year: 2010-11]

For Appellant: 5. That the

Section 147Section 148

circumstance of the appellant's case, the id. AQ erred in law in making addition of Rs. 57,69,920/- as unexplained investment and thereby raising demand of Rs. 33,61,870/- vide order dated: 24.11.2017 ignoring the fact that the said amount was paid directly by the purchaser ... order dated 24.11.2017 was passed by the Assessing Officer (AO) u/s 147/144 of the Act making an addition of Rs.57,69,920/- as an unexplained investment in respect of an information received in respect of purchase of an immovable property in Noida. 3.1. Aggrieved with the order, the assessee filed

Sanjeev Kumar Goyal, Fatehabad vs. DCIT, CC-2, Ludhiana

In the result, the appeal of the assesse is allowed

ITA 80/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By The Order Of The Ld. Cit(A) Dt. 20/01/2023 In Appeal No. 10853/2018-19/It/Cit(A)-5/Ldh/2021-22 For The A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 20/01/2023 Which Is Hereinafter Referred To As The Impugned Order.

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. DR

Section 143(2)Section 250(6)Section 253Section 68

sufficient for the assessee to establish the source of investment is from the business income. The head of surrender relates to the unexplained investment in construction of building is covered under section 69B r.w.s. 115BBE of the Income -tax Act. Vide show cause notice dated 19.09.2021 assessee was show caused ... surrendered amount of Rs. 38,00,000/- on account of construction of building may be treated as unexplained investment and should be taxed as per the provisions of section 115BBE of the Income-tax Act, 1961. 5.3 In response to notice dated 19.09.2021 the assessee submitted his reply dated

Rajiv Kumar Goyal, Dhuri vs. DCIT, CC-2, Ludhiana

In the result, the appeal of the assessee is allowed

ITA 79/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. D.R

Section 133ASection 139(1)Section 250(6)Section 253

having accepted that the sources are unexplained and thus the preponderance of probability is that such investment in excess stock is considered as unexplained investment of the assessee u/s 69B of the Income Tax Act. And as the income is to be assessed u/s 69B of the Income ... account of excess stock found during the course of survey is not considered to be business income of the assessee but considered as unexplained investment not fully disclosed in the books of the accounts of the assessee u/s 69B of the Income Tax Act, and charged

Shri Mohanlal Sondabhai Solanki, Mahuva vs. The Income Tax Officer, Ward-6, Bhavnagar

In the result, ground no.8 of the assessee’s appeal is dismissed

ITA 930/AHD/2017[1998-99]Status: DisposedITAT Ahmedabad22 May 2024AY 1998-99

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year: 1998-99

Section 144Section 68

being peak balance out of addition of A.Y. 1998-99 Page 2 of 9 Rs.36,94,526/- made on account of alleged unexplained investment. The addition retained is totally unjustified on facts as also in law, which may kindly be deleted. 4.0 The learned CIT(A) erred on facts ... retaining addition of Rs.11,591/- out of addition of Rs.6,26,189/- made on account of alleged interest income on above unexplained investment. The addition retained is totally unjustified on facts as also in law which may kindly be deleted. 5.0 The learned cm*omega erred on facts as also

Krishna Chandra Mondal, Chinsurah vs. ACIT, Cir. 23(1), Hooghly

In the result, the appeal filed by the assessee is allowed in the terms indicated herein above

ITA 58/KOL/2024[2013-14]Status: DisposedITAT Kolkata22 May 2024AY 2013-14

Bench: Dr. Manish Borad

Section 143(2)Section 144BSection 147Section 148Section 151Section 250Section 69

confirming the action of the AO in making addition of Rs. 37,20,000/-as investment in property from alleged undisclosed sources as unexplained investment u/s 69 when the actual investments being 50% share of the assessee was duly recorded in the balance sheet and no evidence has been brought

Kishan Singh, Jhajjar vs. ITO, Ward-2, Rohtak

In the result, the appeal of the assessee is dismissed

ITA 768/DEL/2020[2010-11]Status: DisposedITAT Delhi22 May 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Vimal Kumarkishan Singh, Vs. Ito, Vpo-Jakhoda, Tehsil- Ward-2, Bahadurgarh, Distt. Jajjar, Rohtak Bahadurgarh, Haryana (Appellant) (Respondent) Pan: Dqlps9421M Assessee By : Shri Naveen Gupta, Adv Revenue By: Shri Sandeep Kr. Mishra, Sr. Dr Date Of Hearing 13/05/2024 Date Of Pronouncement 22/05/2024

For Appellant: Shri Naveen Gupta, AdvFor Respondent: Shri Sandeep Kr. Mishra, Sr. DR

Section 144Section 147

assessment is hereby dismissed. 5. The assessee vide ground No. 3 and 4 had challenged the sustenance of addition of ₹13 lakhs towards unexplained investment in the property by the ld CIT(A). 6. We have heard the rival submissions and perused the material available on record ... Chander Bhan. The assessee’s share in the agricultural land is 50%. The ld AO added the entire value at ₹76.13 lakhs as an unexplained investment by the assessee, which was reduced to ₹13 lakhs by the ld CIT(A) in following manner:- 50% share of value of property

Mohammed Khalid Masud, Kolkata vs. ACIT, Cir-33, Kolkata.

In the result, the appeal of the assessee stands allowed

ITA 171/KOL/2024[2017-18]Status: DisposedITAT Kolkata21 May 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.171/Kol/2024 (Assessment Year: 2017-18) Mohammed Khalid Masud……..…..……............…...……………....Appellant 70, Karaya Road, Circus Row Kolkata - 700019. [Pan:Afapm6677G] Vs. Acit, Circle-33, Kolkata…...............................................…..…..... Respondent Appearances By: Shri Abhishak Bansal, Ca Appeared On Behalf Of The Appellant. Shri Divakar Chakraborty, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 15, 2024 Date Of Pronouncing The Order : May 21 , 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.11.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Appeal Is Time Barred By 389 Days. A Separate Application For Condonation Of Delay Has Been Filed, Which Is Further Supported By An Affidavit Of The Petitioner Namely Mohammed Khalid Masud. Considering The Submissions Made In The Affidavit, The Delay In Filing The Appeal Is Hereby Condoned.

Section 250Section 50CSection 50C(2)

value of investment by the assessee in the purchase of the property by way of bringing material documentary evidence on record to establish the unexplained investment in the property by the assessee. Merely, rejection of the reply of assessee without giving valid reasons cannot justify the action of the subordinate

Balasubramaniam Palaniappan, Erode vs. ITO, Ward 1(5), Erode

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

ITA 1398/CHNY/2023[2017-18]Status: DisposedITAT Chennai21 May 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1398/Chny/2023. (िनधा"रणवष" / Assessment Year: 2017-18) Balasubramaniam Palaniappan, Vs. The Income Tax Officer, No.10, Narayanasamy Street, Ward 1(5) N.G.G.O. Colony, Surampatti, Erode. Erode 638 009. [Pan: Aljpp 2779F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : None ""यथ" क" ओर से /Respondent By : Shri Arv Srinivasan, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 15.05.2024 घोषणा क" तार"ख /Date Of Pronouncement : 21.05.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: NoneFor Respondent: Shri ARV Srinivasan, IRS, Addl. CIT

Section 142(1)Section 144Section 234CSection 44ASection 69A

explanation furnished by the assessee in part and accordingly divided cash deposits found in her bank account into two parts, i.e one from unexplained investments and the other from out of business receipts. Insofar as unexplained investments, the Assessing Officer has arrived at peak credit on a particular date ... mace addition u/s.69 of the Act as unexplained investments. The balance amount of cash deposits has been accepted as business receipts and has estimated 8% net profit by applying presumptive profit u/s.44AD of the Act. It was the contention of the assessee that once bank credit is accepted as turnover

Swapnil Rajaram Kolambe, Jalgaon vs. ACIT, Central Circle-1, Nashik

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

ITA 556/PUN/2024[2018-19]Status: DisposedITAT Pune20 May 2024AY 2018-19

Bench: Shri Inturi Rama Raoआयकर अपील सं. / Ita No.556/Pun/2024 "नधा"रण वष" / Assessment Year : 2018-19

For Respondent: None

Section 115BSection 133ASection 143(3)Section 69

passed u/s.143(3) at a total income of Rs.38,18,920/-. The assessed income includes addition of Rs.9,80,780/- on account of unexplained investments as discussed vide para 12 of the assessment order. The income was assessed to tax based on the admission made by the assessee during

Krishnappa Govindappa, Bengaluru vs. Income Tax Officer, Ward-4(2)(1), Bengaluru

In the result, the appeal of the assessee is allowed

ITA 416/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri R. Chandrashekar, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel

Section 69Section 69A

course of computing tax which is essential part of raising demand u/s 156 for completing the assessment, then the AO cannot treat it as unexplained investment u/s. 69A. Accordingly we accept the plea of the assessee that income should be considered as agricultural income and apply normal tax rate

Akar Laminators Limited, Ahmedabad vs. The ITO, Ward-1(1)(1) (Astt. Order Passsing Authority) Deputy Commissioner of Income Tax, Circle 1(1)(1) (Current Jurisdiction), Ahmedabad

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

ITA 717/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad17 May 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

For Appellant: Shri Sunil Talati, A.RFor Respondent: Shri H. Phani Raju, CIT D.R. & Ms. Saumya Pandey

Section 144Section 148Section 68

raised the following grounds of appeal: “1. The Ld. CIT(A) has erred in confirming an addition of Rs. 21,16,73,489/- as unexplained investment from the undisclosed source of income u/s. 68 of the Income Tax Act, 1961. It is submitted that the said loans and advances were ... given. 17. In the absence of the above details, the AO treated the amount of advances made during the year under consideration as an unexplained investment and added to the total income of the assessee. 18. Aggrieved assessee preferred an appeal to the ld. CIT-A who confirmed the order

Akar Laminators Limited, Ahmedabad vs. The ITO, Ward-1(1)(1) (Asstt. Order Passing Authority) Deputy Commissioner of Income Tax, Circle 1(1)(1) (Current Jurisdiction), Ahmedabad

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

ITA 716/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad17 May 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

For Appellant: Shri Sunil Talati, A.RFor Respondent: Shri H. Phani Raju, CIT D.R. & Ms. Saumya Pandey

Section 144Section 148Section 68

JCIT(OSD), Central Circle-3(4), Chennai vs. Late Shri Venkataram Raddy Bezawada Rep by L/H Smt. B. Kamakshi (Wife )& Others, Nellore

In the result, the assessee’s appeal for AYs 2006-07 to 2010-2011

ITA 36/CHNY/2023[2008-09]Status: DisposedITAT Chennai17 May 2024AY 2008-09

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.951/Chny/2022 (िनधा"रण वष" / Assessment Year: 2006-07) & 2. आयकरअपील सं./ Ita No.952/Chny/2022 (िनधा"रण वष" / Assessment Year: 2007-08) & 3. आयकरअपील सं./ Ita No.953/Chny/2022 (िनधा"रण वष" / Assessment Year: 2008-09) & 4. आयकरअपील सं./ Ita No.954/Chny/2022 (िनधा"रण वष" / Assessment Year: 2009-10) & 5. आयकरअपील सं./ Ita No.955/Chny/2022 (िनधा"रण वष" / Assessment Year: 2010-11) & 6. आयकरअपील सं./ Ita No.956/Chny/2022 (िनधा"रण वष" / Assessment Year: 2011-12) & 7. आयकरअपील सं./ Ita No.957/Chny/2022 (िनधा"रण वष" / Assessment Year: 2012-13) Smt. B.Kamakshi Dcit [L/H Of Shri Bezwada Venkatram Central Circle -3(4), Reddy (Deceased)] Chennai. बनाम/ Vs. Flat F3, Prakruthi Apartments, 20, Dr.Ranga Road, Mylapore Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Agdpb-3601-R

For Appellant: Shri B. Ramakrishnan (CA)- Ld.ARFor Respondent: Smt. Komali Krishna (CIT)-Ld. DR

Section 153ASection 234A

Rs.623.10 Lacs relating to four group companies. 2.8 In AY 2011-12, the only addition made by Ld. AO was substantive addition of unexplained investment u/s 69A for Rs.26.62 Lacs. The same represent additional deposits in the two bank accounts. In the absence of any satisfactory reply forthcoming from