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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

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 84/IND/2014[1991-97]Status: DisposedITAT Indore18 Mar 2024AY 1991-97

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

source of income for making such investments. By now it is an established law that revenue need not locate the source of investment if unexplained investment is detected. Shri Panjwani has clearly admitted making of investment inn bogus names for various years out of income from Panjwani Packagings Limited ... Panjwani Plastics & Polyster Ltd.: 30. In this ground, the assessee challenges the addition of Rs. 2,32,000/- made by AO on account of unexplained investment by assessee in shares of M/s Panjwani Plastics and Polysters Ltd. 31. The AO has dealt this issue in Para 5.4 of assessment-order

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 83/IND/2014[1990-91]Status: DisposedITAT Indore18 Mar 2024AY 1990-91

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

source of income for making such investments. By now it is an established law that revenue need not locate the source of investment if unexplained investment is detected. Shri Panjwani has clearly admitted making of investment inn bogus names for various years out of income from Panjwani Packagings Limited ... Panjwani Plastics & Polyster Ltd.: 30. In this ground, the assessee challenges the addition of Rs. 2,32,000/- made by AO on account of unexplained investment by assessee in shares of M/s Panjwani Plastics and Polysters Ltd. 31. The AO has dealt this issue in Para 5.4 of assessment-order

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 82/IND/2014[1989-90]Status: DisposedITAT Indore18 Mar 2024AY 1989-90

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

source of income for making such investments. By now it is an established law that revenue need not locate the source of investment if unexplained investment is detected. Shri Panjwani has clearly admitted making of investment inn bogus names for various years out of income from Panjwani Packagings Limited ... Panjwani Plastics & Polyster Ltd.: 30. In this ground, the assessee challenges the addition of Rs. 2,32,000/- made by AO on account of unexplained investment by assessee in shares of M/s Panjwani Plastics and Polysters Ltd. 31. The AO has dealt this issue in Para 5.4 of assessment-order

Kamal Panjwani, Indore vs. The ACIT 3 (1), Indore

ITA 81/IND/2014[1988-89]Status: DisposedITAT Indore18 Mar 2024AY 1988-89

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

Section 132Section 132(4)Section 143(3)Section 147Section 148Section 254

source of income for making such investments. By now it is an established law that revenue need not locate the source of investment if unexplained investment is detected. Shri Panjwani has clearly admitted making of investment inn bogus names for various years out of income from Panjwani Packagings Limited ... Panjwani Plastics & Polyster Ltd.: 30. In this ground, the assessee challenges the addition of Rs. 2,32,000/- made by AO on account of unexplained investment by assessee in shares of M/s Panjwani Plastics and Polysters Ltd. 31. The AO has dealt this issue in Para 5.4 of assessment-order

Anoopkumar Devidas Raimalani, Mumbai vs. ITO, Cir-18(1), Mumbai

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

ITA 1653/MUM/2023[2014-15]Status: DisposedITAT Mumbai15 Mar 2024AY 2014-15

Bench: Shri Narender Kumar Choudhry, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 143(3)Section 250Section 253(2)

Since arranging such unexplained cash credit necessarily entails payment of commission to entry providers, the AO's action in quantifying and adding such unexplained investment towards procurement of such entries amounting to Rs 1,17,33,011/- is also upheld as reasonable and Justified in the facts of the case

DCIT Central Circle-32, Delhi vs. Rnb Mercantile Pvt. Ltd., Delhi

In the result, the appeal of the Revenue is dismissed

ITA 843/DEL/2022[2011-12]Status: DisposedITAT Delhi14 Mar 2024AY 2011-12

Bench: Shri Shamim Yahya & Shri Y0Gesh Kumar Usdcit, Central Circle 32, Vs. Rnb Mercantile Pvt. Ltd., Delhi. House – 1, Shivaji Enclave, Main Road, Opp. Mother Dairy Near Raja Garden, New Delhi – 110 027. (Pan : Aabcr9334G) (Appellant) (Respondent)

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri P.N. Barnwal, CIT DR
Section 153ASection 68

against the returned income of Rs.5,62,330/- by making an addition of Rs.6,34,00,000/- on account of unexplained investment in shares under section 68 of the Act. Upon assessee’s appeal, ld. CIT (A) noted that addition was made de hors 4. of any incriminating material found

Prabha Rajput, Bhopal vs. ITO-3(1), Bhopal

ITA 479/IND/2023[2007-08]Status: DisposedITAT Indore12 Mar 2024AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniprabha Rajput Ito-3(1) Katara Bag Mugaliya Bhopal Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Bzgpr2626 R Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.03.2024 Date Of Pronouncement 12.03.2024

Section 147Section 69

erred in confirming the action of Assessing Officer in making addition of Rs.17,65,500/- u/s 69 of the Act on account of unexplained investment which was jointly acquired with Smt. Kamla Bai to the appellant and is therefore unjust, illogical and arbitrary and deserves to be quashed. 4 That ... erred in confirming the action of Assessing officer in making addition of Rs.17,65,500/- u/s 69 of the Act on account of unexplained investment in the purchase of land and therefore it is unjust, illogical and arbitrary and deserves to be quashed. 5.It is prayed that the assessment order

Rrp Ventures Pvt. Ltd., Chennai vs. Income Tax Officer, Corporate Ward-5(3), Chennai

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

ITA 714/CHNY/2023[2013-14]Status: DisposedITAT Chennai12 Mar 2024AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Ms.N.V. Lakshmi, AdvocateFor Respondent: Shri N. Balakrishnan, CIT
Section 115JSection 132Section 139(1)Section 153ASection 153C

money to the extent of Rs.69,42,000/-, which is not recorded in the books of accounts and hence, the same was treated as unexplained investment u/s.69 of the Act and added to the returned income of the assessee. Aggrieved, assessee preferred appeal before ... eviction and clearing of encroachments is without any evidence and only afterthought. Hence, we find that no possible explanation or evidence that this unexplained investment of Rs.69.42 lakhs admitted by the AO and confirmed by the CIT(A) has no basis for deletion. Hence, we confirm the order

Late Smt. Sudershan Kapoor (Through Legal Heir Shammi Kapoor), Noida vs. ITO Ward-3(4, Noida

In the result, appeal of the assessee is allowed

ITA 3255/DEL/2023[2009-10]Status: DisposedITAT Delhi12 Mar 2024AY 2009-10

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.3255/Del/2023 िनधा"रणवष"/Assessment Year: 2009-10 बनाम Late Smt. Sudershan Kapoor Ito, (Through Legal Heir Shammi Kapoor) Vs. Ward-3(4), 1701, Ground Floor, Aaykar Bhawan, Ats Greens Village, A2D, Sector-24, Sector-93A Express Way Noida, Noida, Noida, Uttar Pradesh. Uttar Pradesh. Pan No. Aeqpk2478G अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 144Section 271(1)(c)Section 69

submits that the assessment made u/s 143(3) of the Act making addition of Rs.41,36,250/- u/s 69 of the Act as an unexplained investment has been deleted by the Ld.CIT(A) which ordered was also sustained by I.T.A.No.3255/Del/2023 the Tribunal in ITA No.2364/Del/2019 dated 15.05.2020. Therefore ... assessment u/s 144/148 of the Act dated 18.11.2016 an addition of Rs.41,36,250/- was made u/s 69 of the Act as an unexplained investment on the investment made in the purchase of immovable property. This addition was deleted by the Ld.CIT(A) and the order of the Ld.CIT

Pradeep Kumar, Noida vs. ITO, Ward-2(4), Noida

In the result, the appeal of the assessee stands allowed for

ITA 1395/DEL/2023[2011-12]Status: DisposedITAT Delhi12 Mar 2024AY 2011-12

Bench: Shri Shamim Yahya & Shri Yogesh Kumar Us[Assessment Year: 2011-12]

Section 147Section 148Section 148(2)Section 151Section 234BSection 251

facts in confirming the addition of Rs. 39,66,000/- made by the Ld. Assessing Officer on account of alleged unexplained investment in purchase of immovable property, without properly appreciating facts of the case. 3. That having regard to the facts and circumstances of the case, the Learned Commissioner

Rani Goenka, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1414/KOL/2023[2012-13]Status: DisposedITAT Kolkata11 Mar 2024AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 147Section 148Section 68

assessee has challenged the confirmation of addition of Rs. 1,37,00,000/- as made by the AO u/s 68 on account of unexplained investment which is contrary to the evidences on record and has to be deleted. 2 I.T.A. No. 1414/Kol/2023 Assessment Year: 2012-13 Rani Goenka 3. Facts ... counsel were taken into account and finally the sum of Rs. 1,37,00,000/- was added to the income of the assessee as unexplained investment u/s 68 of the Act. 4. The case of the assessee was simply dismissed on legal issue as well as on merit

Jagadish Kumar P.V (Legal Heir of Late Rema Padmaja Bai), Trivandrum vs. ACIT Circle 2(1), Trivandrum

In the result, the assessee’s appeal is partly allowed and partly allowed for statistical purposes

ITA 376/COCH/2023[2016-17]Status: DisposedITAT Cochin11 Mar 2024AY 2016-17

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmijagadish Kumar P.V. Asst. Cit, Circle - 2(1) (L/H Of Rema Padmaja Bai) Thiruvananthapuram Sree, T.C. 50/899(1), Kalady Vs. Hsra A-56, Karamana P.O. Thiruvananthapuram [Pan:Aempp5283J] (Appellant) (Respondent)

For Appellant: Shri Raja Kannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 69

examined with reference to each separate sum stated in explanation of the source of investment in house property and, accordingly, deemed as income as unexplained investment u/s. 69 of the Act. 5.2 Our first preliminary observation, also made during hearing, to no satisfactory answer by Shri Kannan

Alchemist Touchnology, New Delhi vs. ACIT, Central Circle-20, New Delhi

ITA 1689/DEL/2022[2013-14]Status: DisposedITAT Delhi11 Mar 2024AY 2013-14

Bench: Shri C. N. Prasad & Shri M. Balaganeshalchemist Touchnology, Vs. Acit, Building No. 23, Nehru Central Circle-20, Place, Alchemist House, Delhi South Delhi-110019 (Appellant) (Respondent) Pan:Aaica1617Q Assessee By : Shri N. K. Lal, Ca Revenue By: Shri Zafarul Haque Tanweer, Cit Dr Date Of Hearing 10/01/2024 Date Of Pronouncement 11/03/2024

For Appellant: Shri N. K. Lal, CAFor Respondent: Shri Zafarul Haque Tanweer, CIT DR
Section 132Section 153ASection 153CSection 153DSection 245D(1)Section 69

confirming the action of the Ld. AO, by making ad-hoc additions of Rs. 119,88,60,000/- u/s 69 of the Act as unexplained investments on mere surmises, conjectures and without first pointing out to the appellant company. 6. That on law, facts and circumstances of the case ... since the money has been sent to secure such funds through FDI route, the same has to be considered as unexplained investment in terms of provisions contained in section 69 of the Act. The ld. AO accordingly made an addition

Darshan Kishore Sangulkar, Thane vs. ITO Ward 2, Kalyan

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

ITA 3834/MUM/2023[25/10/2023]Status: DisposedITAT Mumbai08 Mar 2024

Bench: Us Ld. Counsel Submitted That Here In This Case Exparte Assessment Order Was Passed U/S.144 On The Ground That Assessee Had Not Responded To The E-Mail Sent By The Ld. Ao & Accordingly, Additional Amount Of Unexplained Investment Of Rs.53,30,000/-

Section 142(1)Section 144Section 147

passed u/s.144 on the ground that assessee had not responded to the e-mail sent by the ld. AO and accordingly, additional amount of unexplained investment of Rs.53,30,000/- 2 Darshan Kishor Sangulkar has been made and addition of unexplained cash deposits and undisclosed salary aggregating to Rs.26

ACIT, Circle CC 15, New Delhi vs. Alka Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1864/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

later date, cannot perse, on its own and without any corroborative evidence on record lead to any presumption or assumption of any unexplained investment. The fact that this property as referred in the said proposed ATS was purchased by the Appellant and the spouse of the' Appellant from the parties ... found in the possession or control of that person in the course of a search under section 132." 13.2 Section 69 read as under:- "Unexplained investments 69. Where in the financial year immediately preceding the assessment year the assessee has made investments which are not recorded in the books

ACIT, CC-15, New Delhi vs. Yash Pal Mendiratta, Delhi

In the result, the appeals of the Revenue are dismissed and the Cross Objections of the assessees are also dismissed

ITA 1863/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Mar 2024AY 2016-17

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: Sh. Amit Goel, CA &For Respondent: Ms. Sapna Bhatia, CIT-DR
Section 153ASection 69

later date, cannot perse, on its own and without any corroborative evidence on record lead to any presumption or assumption of any unexplained investment. The fact that this property as referred in the said proposed ATS was purchased by the Appellant and the spouse of the' Appellant from the parties ... found in the possession or control of that person in the course of a search under section 132." 13.2 Section 69 read as under:- "Unexplained investments 69. Where in the financial year immediately preceding the assessment year the assessee has made investments which are not recorded in the books

State Organisation of Gyn and Obs of Gujarat, Ahmedabad vs. The ITO (Exemp), Bhavnagar Now the ITO, Ward-1(1)(3), Ahmedabad

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

ITA 1126/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad06 Mar 2024AY 2012-13

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 State Organization Of Gyn Ito (Exemption) & Obs Of Gujarat Bhavnagar Ama Building, Now Ito-Ward(1)(1)(3) Nr.Natraj Cinema Ahmedabad. Ashram Road Ahmedabad 380 009. Pan : Aaats 9145 A (Applicant) (Responent)

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Ketan Gajjar, Sr.DR
Section 144Section 148Section 250(6)

addition of Rs.10,09,542/- made by the assessing Officer treating the fixed deposits with the Bank made in earlier year as alleged unexplained investment. 6. The learned Commissioner of Income Tax (Appeals), NFAC, Delhi has erred in confirming the addition of Rs.23,85,078/- made by the assessing Officer

Ghisudas, Bangalore vs. Income-Tax Officer, Ward- 5(2)(5), Bangalore

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

ITA 216/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Mar 2024AY 2017-18

Bench: SHRI LAXMI PRASAD SAHU (Accountant Member), SHRI SANDEEP SINGH KARHAIL (Judicial Member)

For Appellant: Shri A.S. Vishnu Bharath, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 133(6)Section 143(3)Section 44ASection 69A

however he submitted reply to the final show cause notice. The AO has treated the difference amount of turnover and cash deposit as unexplained investment u/s. 69A to which the CIT(Appeals) has confirmed. Before the CIT(Appeals) written submissions were made and the assessee did not respond

Mr Vicky Murli Advani, Mumbai vs. Income Tax Officer (Int. Tax) Ward 1(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3664/MUM/2023[2015-16]Status: DisposedITAT Mumbai04 Mar 2024AY 2015-16

Bench: Shri Kuldip Singh & Shri Amarjit Singhmr. Vicky Murli Advani Vs. Income Tax Officer, T3-3202, Runval Greens, International Tax, Rosewood, Near Fortis Ward1(1)(1), Hospital, Mulund Room No. 1817A, 18Th Goregaon Link Road, Floor, Air India Bldg. Mulund West- 400 078 Nariman Point, Mumbai – 400021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Agypa7741A Appellant .. Respondent Appellant By : Rajesh Sanghvi Respondent By : S. Arunkumar Date Of Hearing 27.02.2024 Date Of Pronouncement 04.03.2024

For Appellant: Rajesh SanghviFor Respondent: S. Arunkumar
Section 132(1)Section 132(4)Section 143(2)Section 143(3)Section 147Section 148Section 69

Appeals) erred in upholding the action of the AO for treating the amount of Rs. 33,56,250/- as unexplained investment u/s 69 on account of "On Money" paid to developer M/s Runwal Homes Pvt Ltd for purchase of Flat, ignoring the submission made by the appellant and confirm ... obtained during the course of search proceedings.” Therefore, an amount of Rs.33,56,250/- was added to the total income of the assessee company unexplained investment u/s 69 of the Act. 3. The assessee filed the appeal before the ld. CIT(A). The ld. CIT(A) has dismissed the appeal

Bharat Laxman Bhiwapurkar, Thane vs. ITO, Ward 1(5), Thane

In the result, the appeal of the assesse is partly allowed

ITA 3413/MUM/2023[2011-12]Status: DisposedITAT Mumbai04 Mar 2024AY 2011-12

Bench: Shri Kuldip Singh & Shri Amarjit Singhbharat Laxman Vs. Ito, Ward 1(5), Bhiwapurkar, 204, Room No. 14, B Wing, Oxford, Regency Heights, 6Th Floor, Ashar It Park, Azad Nagar, Kolshet, Road No. 16Z, Wagle, Thane - 400602 Ind. Estate, Thane-400604 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Abnpb8487A Appellant .. Respondent Appellant By : Subodh Ratnaparkhi Respondent By : S. Arunkumar Date Of Hearing 26.02.2024 Date Of Pronouncement 04.03.2024 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Cit(A) Nfac, Dated 03.08.2023 For A.Y. 2011-12. The Assessee Has Raised The Following Grounds Before Us: “1. The Hon. Cit (A) Erred In Upholding Re-Opening Of Assessment U/S 147 Of The Income Tax Act 1961, Inspite Of The Fact That There Was No Incriminating Material Pertaining To The Appellant With Regards To Alleged On-Money Paid For Purchase Of Flat From Cosmos Group & Therefore The Re-Opening Was In Absence Of Any Independent & Valid Belief On The Part Of The Id Ao That Any Income Chargeable To Tax Had Escaped Assessment. The Re-Opening Of Assessment U/S 147 Being Bad-In-Law, The Asst. Order Flowing Therefrom, Being The Order U/S 143(3) R.W.S 147 Is Also Invalid & Bad In Law & Hence The Same May Be Quashed 2. The Hon Cit (A) Erred In Upholding The Addition Of Rs. 31,00,000/-, U/S 69 Of The 1.1 Act, 1961, As Unexplained Investment Towards Alleged On- Money Paid Towards Purchase Of Flat No. A-07, 7Th Floor, Twilight, Cosmos Horizon, Ghodbunder Road, Thane (W) To Cosmos Group, Ignoring The Contentions Of The Appellant That There Was No Incriminating

For Appellant: Subodh RatnaparkhiFor Respondent: S. Arunkumar
Section 131Section 132(4)Section 143(1)Section 143(3)Section 147Section 148Section 69

quashed 2. The Hon CIT (A) erred in upholding the addition of Rs. 31,00,000/-, u/s 69 of the 1.1 Act, 1961, as unexplained investment towards alleged on- money paid towards purchase of flat no. A-07, 7th floor, Twilight, Cosmos Horizon, Ghodbunder Road, Thane (W) to Cosmos Group ... given on money of Rs.31,00,000/- for purchase of flat. Therefore, the AO has added the amount of Rs.31,00,000/- as unexplained investment deemed to be the income of the assessee for the year under consideration. 3. The assessee filed the appeal before