“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

Geetha Mehra, Chennai vs. DCIT Cen Cir 44, Mumbai

In the result, the appeals of the assessee for assessment year

ITA 4035/MUM/2016[2002-03]Status: HeardITAT Mumbai21 Nov 2022AY 2002-03

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2002-03 & Assessment Year: 2003-04 & Assessment Year: 2004-05 & Assessment Year: 2005-06 & Assessment Year: 2006-07 & Assessment Year: 2007-08 Ms. Geetha Mehra, Acit (3)(1)(1), C/O Synergy Art Foundation Ltd., Room No. 607, Aayakar Vs. 6/19 Ii Floor, Grants Building Bhavan, Maharshi Karve Arthur Bunder Road, Colaba, Road, Mumbai-400 005. Mumbai-400020. (Formerly Deputy Commissioner Of Income Tax, Central Circle 44) Pan No. Aagpm 9039 H Appellant Respondent : Assessee By Mr. Ajay Ghone, Ar : Revenue By Mr. Kailash Kanojia, Cit-Dr Date Of Hearing : 25/08/2022 : Date Of Pronouncement 21/11/2022

For Respondent: Assessee by Mr. Ajay Ghone, AR

Section 13Section 132Section 143(3)Section 153A

mentioned that addition of ssment order has mentioned that addition of ssment order has mentioned that addition of ₹14,62,500/-is an unexplained investment under section 69 of is an unexplained investment under section 69 of is an unexplained investment under section 69 of Act Geetha Mehra king

M/S. Mukka Protenis Limited, Mangaluru vs. Principal Commissioner of Income Tax, Central, Bangalore

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

ITA 433/BANG/2022[2018-19]Status: DisposedITAT Bangalore17 Nov 2022AY 2018-19

For Appellant: Shri V. Srinivasan, Advocate

Section 115BSection 143Section 153DSection 263Section 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

Subahan Abdul Majzeeth, Chennai vs. ITO, Ncw-10(1), Chennai

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

ITA 3337/CHNY/2018[2015-16]Status: DisposedITAT Chennai16 Nov 2022AY 2015-16

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकरअपीलसं./Ita No.: 3337/Chny/2018 िनधा"रण वष"/Assessment Year: 2015 - 16 Shri Subahan Abdul The Income Tax Officer, Majzeeth, Vs. Non-Corporate Ward 10(1), F1, Prp Block-Rose Park, Chennai. No.10, Santhi Nagar, 1St Cross, Adambakkam, Chennai – 600 088. Pan: Agmpa 9389E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sathyanarayanan,Advocate ""यथ" क" ओर से/Respondent By : Shri Ar.V. Sreenivasan, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 14.11.2022 घोषणा क" तार"ख/Date Of Pronouncement : 16.11.2022 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-12, Chennai In Ita No.26/Cit(A)-12/2017-18 Dated 28.09.2018. The Assessment Was Framed By The Ito, Non-Corporate Ward 10(1), Chennai For The Assessment Year 2015-16 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 02.11.2017. 2. At The Outset, It Is Noticed That This Appeal Is Barred By Limitation By 1 Day & The Assessee Has Filed Condonation Petition Stating The Reason That Due To Time Involved In Collecting The Papers From Assessee’S Chartered Accountant & To Hand Over The Same To His Advocate, There Was A Delay Of One Day In Filing Of This Appeal Before The Tribunal. When This Was Confronted To Ld.Senior Dr, He Could Not Object. Hence, We Condone The Delay & Admit The Appeal.

For Appellant: Shri S. Sathyanarayanan,AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT

Section 143(3)Section 69

purchase account amounting to Rs.27,16,501/- is nothing but suppression of purchases. Therefore, the AO added this amount of Rs.29,05,664/- as unexplained investment u/s.69 of the Act by noting in para 19 as under:- “19. In view of the above findings, the total purchases is taken ... CBEC and the Total Purchases as per P&L A/c amounting to Rs.29,05,644 (Rs.5189330 – 2283686) is added to the total income as Unexplained Investments u/s.69.” Aggrieved, assessee preferred appeal before the CIT(A). 5. The CIT(A) after examining the submissions of the assessee confirmed the addition

Satguru Iron & Steel Company, Mumbai vs. Principal Commissioner of Income Tax, Mumbai

In the result, the appeal of the assessee is allowed

ITA 987/MUM/2022[2017-18]Status: DisposedITAT Mumbai10 Nov 2022AY 2017-18

Bench: Shri B. R. Baskaran, Am & Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.987/Mum/2022 (निर्धारण वर्ा / Assessment Years: 2017-18) Satguru Iron & Steel बिधम/ Pcit-8 Company Pvt. Ltd. Room No. 611, 6Th Floor, Vs. 205, Sujata Chambers Off, Aayakar Bhavan, Katha Bazar Masjid (W), Maharishi Karve Road, 2Nd Floor, 1/3 Abhichand Mumbai-400020. Gandhi Marg, Mumbai- 400009. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aalcs0501Q (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vijay Mehta Revenue By: Shri Manoj Kumar (Dr) सुनवाई की तारीख / Date Of Hearing: 04/10/2022 घोषणा की तारीख /Date Of Pronouncement: 10/11/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax-8 [Hereinafter Referred To As The “Pcit”], Mumbai Dated 11.03.2022 For Assessment Year 2017-18 Passed Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: Shri Vijay MehtaFor Respondent: Shri Manoj Kumar (DR)

Section 143(3)Section 263

According to the Ld. PCIT, the assessee’s investment in un-listed shares of M/s. Morya Erectors Pvt. Ltd. was in the nature of unexplained investment in the books of assessee in view of Section 69 of the Act. And therefore, according to Ld. PCIT, Rs.4 ... required to be added back to the total income of assessee being unexplained investment. Therefore, according to him since the AO has not taxed the said amount the assessment order of AO was erroneous as well as prejudicial to the revenue. 5 A.Y. 2017-18 Satguru Iron & Steel Company

DCIT- CC- 6(2), Mumbai vs. Samira Habitats India Ltd., Mumbai

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

ITA 1365/MUM/2022[2011-12]Status: DisposedITAT Mumbai07 Nov 2022AY 2011-12

Bench: Shri S. Rifaur Rahman, Am & Ms. Kavitha Rajagopal, Jm Dy. Cit-Central Circle-6(2) Samira Habitats India Ltd. Mumbai G-8, Shrikant Chambers, Vs. Sion Trombay Road, Chembur, Mumbai-400 071 Pan/Gir No. Aabcs 1677 F (Appellant) : (Respondent)

For Respondent: Shri Achal Sharma

Section 143(2)Section 144Section 153CSection 245D(1)Section 250

addition of Rs.4,28,70,000/- by the ld. CIT(A), which was made by the Assessing Officer (‘A.O.’ for short) on account of unexplained investment being deposited with Kotak Mahindra Bank, for which the 2 Dy. CIT vs. Samira Habitats India Ltd. assessee has not furnished complete details, explaining ... before the ld. CIT(A). 5. The ld. CIT(A) passed an order, confirming certain additions and deleting certain addition/disallowances. The addition pertaining to unexplained investment in time deposit was deleted by the ld. CIT(A) on the ground that the assessee has proved the source of the investment

Nishith Rameshchandra Shah, Mumbai vs. Income Tax Officer Ward 23(2)(6), Mumbai

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

ITA 1116/MUM/2022[2012-2013]Status: DisposedITAT Mumbai04 Nov 2022AY 2012-2013

Section 10(38)Section 143(3)Section 250Section 68

determining total income of Rs.18,78,540/- where, addition u/s 68 of the Act amounting to Rs.5,76,775/- was made on account of unexplained investment towards sale proceeds of shares of M/s. Diamant Infrastructure Limited during the impugned year. The assessee was in appeal before the learned ... period of few months from buying the shares of unknown company which does not have enough business worth and the same was held as unexplained investment. The assessee is in appeal before us as against the order of the learned CIT(A). P a g e | 3 NISHITH RAMCHANDRA SHAH

Sri Satish C Kandkur, Yadgir vs. Assistant Commissioner of Income Tax Circle-1, Kalaburagi

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 47/BANG/2019[2014-15]Status: DisposedITAT Bangalore03 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Pratibha, A.RFor Respondent: Smt. Priyadarshini Baseganni, D.R

Section 133ASection 68Section 69

assessee as non-agricultural income and also addition of Rs.15 lakhs u/s 69 of the Income-tax Act,1961 ['the Act' for short] as unexplained investment in flats. Against this assessee carried on the appeal before Ld. CIT(A) and the Ld. CIT(A) sustained the addition. Against this, once ... treatment of agricultural income of Rs.1,00,00,000/- as other source of income and (b) adding a sum of Rs.9,79,438/- as unexplained investment within the meaning of Section 69 of the Act. Ld. CIT(A) confirmed the levy of penalty. Against this assessee is in appeal before

Sri.Satish C.Kandkur, Yadgir vs. Assistant Commissioner of Income Tax Circle-1, Gulbarga

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 46/BANG/2019[2013-14]Status: DisposedITAT Bangalore03 Nov 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Pratibha, A.RFor Respondent: Smt. Priyadarshini Baseganni, D.R

Section 133ASection 68Section 69

DCIT Cental Circle 2(3), Chennai vs. Dr. Murugu Sundaram, Chennai

The appeal stand dismissed

ITA 3086/CHNY/2018[2016-17]Status: DisposedITAT Chennai02 Nov 2022AY 2016-17

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate)-Ld. ARFor Respondent: Shri Darzakhum Songate (CIT) –Ld. DR

Section 132Section 132(4)

ground urged by the revenue stand dismissed. 10. The other ground in the appeal is deletion of addition of Rs.7.67 Lacs which represent unexplained investment in Jewellery. As per valuation report, gold jewellery of 815.10 grams and 19.41 carats of diamonds worth Rs.29.24 Lacs was found. Most of the jewellery

DCIT Central Circle 2(3), Chennai vs. Dr. Raja Sundaram, Chennai

The appeal stand dismissed

ITA 3085/CHNY/2018[2016-17]Status: DisposedITAT Chennai02 Nov 2022AY 2016-17

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate)-Ld. ARFor Respondent: Shri Darzakhum Songate (CIT) –Ld. DR

Section 132Section 132(4)

Premalatha Ramu, Chennai vs. ITO, Chennai

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

ITA 836/CHNY/2017[2012-13]Status: DisposedITAT Chennai02 Nov 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 836/Chny/2017 िनधा"रण वष" / Assessment Year:2012-13 Smt. Premalatha Ramu, The Income Tax Officer, No. 33/2, Kalaivanar Colony, V. Non Corporate Ward -7(2), 2Nd Street, Anna Nagar West Chennai. Extension, Chennai – 600 101. [Pan: Agfpr-4525-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. N. Arjun Raj, Ca : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तार"ख/Date Of Hearing : 20.10.2022 घोषणा क" तार"ख/Date Of Pronouncement : 02.11.2022 आदेश /O R D E R Per G. Manjunatha:

For Appellant: Shri. N. Arjun Raj, CA

Section 143(3)Section 68

rejection of explanation for the source were not justified. 5. The CIT (Appeals) erred in sustaining the addition of Rs.19,32,780/- as unexplained investment with regard to the transaction with the appellant's husband for the reasons stated in para 6.3 of the impugned order in the computation ... determined total income of Rs. 74,10,030/-, after making additions towards unexplained cash credit for unsecured loan amounting to Rs. 50 lakhs and unexplained investments towards unsecured loans given to her husband amounting to Rs. 19,32,780/-. The assessee carried the matter in appeal before the first appellate

Raju Tirathdas Ramchandani, Mum vs. Income Tax Officer-22(3)(1), Mum

In the result, the appeal of the assessee is allowed

ITA 2252/MUM/2022[2005-06]Status: DisposedITAT Mumbai31 Oct 2022AY 2005-06

Bench: Shri Vikas Awasthy & Shri Amarjit Singhraju Tirathdas Vs. Income Tax Officer - Ramchandani, 603, 22(3)(1), Piramal Premodyan Co-Op Chamber, Lal Baugh Housing Society, 12Th Parel, Road, Ram Krishna Maharashtra - 400012 Mission, Khar (W) Mumbai – 400 052 स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aebpr3611P Appellant .. Respondent Appellant By : Shashi Bekal Respondent By : Mahita Nair Date Of Hearing 31.10.2022 Date Of Pronouncement 31.10.2022 आदेश / O R D E R Per Amarjit Singh, Am: The Solitary Ground Of Appeal Of The Assessee Is Directed Against The Nfac In Confirming The Levy Of Penalty Of Rs.4,49,922/- U/S 271(1)(C) Of The Act. 2. Fact In Brief Is That Assessment U/S 144 R.W.S 147 Of The Act Was Finalized On 04.03.2013. During The Course Assessment A.O Noticed That Assessee Has Made Total Investment Of Rs.14,00,000/- During The Year In All Templaton India Treasury Management Account Regular Plan – Weekly Dividend Plan Scheme. The A.O Stated That During The Course Of

For Appellant: Shashi BekalFor Respondent: Mahita Nair

Section 143(3)Section 144Section 271(1)(c)Section 274

nature and the source of the investment made was provided by the assessee, therefore, the A.O treated the amount of Rs.14,00,000/- as unexplained investment and added back to the total income of the assessee. The A.O has also initiated penalty ... dated 11.03.2016 the A.O stated that neither assessee attended during the course of penalty proceedings nor filed any explanation for the aforesaid unexplained investment, therefore, penalty to the amount of Rs. 4,49,922/- was levied. 3. Assessee filed appeal before the ld. CIT(A). Even before

Shri Sanjay Shantilal Jain, Mumbai vs. JCIT, Central Range-8, Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is having ITA No

ITA 6124/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2010-11 Shri Sanjay Shantilal Jain, Dcit-Cc 8(3), 72-7, Kalpataru Residency Tower 6Th Floor, Aayakar Bhavan, Vs. B, Sion Koliwada Road, Sion, M.K. Road, Mumbai-400022. Mumbai-400020. Pan No. Aabpj 3761 A Appellant Respondent Assessment Year: 2010-11 Shri Sanjay Shantilal Jain, Jcit, Central Range-8, 72-7, Kalpataru Residency Tower 6Th Floor, Aayakar Bhavan, Vs. B, Sion Koliwada Road, Sion, M.K. Road, Mumbai-400022. Mumbai-400020. Pan No. Aabpj 3761 A Appellant Respondent : Assessee By Mr. Rushabh Mehta, Ar Revenue By : Mr. Manoj Kumar, Cit- Dr : Date Of Hearing 15/09/2022 Date Of Pronouncement : 31/10/2022

For Respondent: Assessee by Mr. Rushabh Mehta, AR

Section 143(3)Section 40A(3)Section 50Section 68Section 69C

wherever unaccounted investment/expenditure expenditure is explained by way of undisclosed receipt, is explained by way of undisclosed receipt, then no separate addition for such unexplained investment or then no separate addition for such unexplained investment then no separate addition for such unexplained investment expenditure should be made. Since

Shri Sanjay Shantilal Jain, Mumbai vs. DCIT, Central Range-8 (3), Mumbai

In the result, the appeal of the In the result, the appeal of the assessee is having ITA No

ITA 6123/MUM/2018[2010-11]Status: DisposedITAT Mumbai31 Oct 2022AY 2010-11

For Respondent: Assessee by Mr. Rushabh Mehta, AR

Section 143(3)Section 40A(3)Section 50Section 68Section 69C

Assistant Commissioner of Income Tax Central Circle - 1(4), Bengaluru vs. M/S Snowshine Realtors Pvt.Ltd., Bengaluru

In the result, the revenue appeals in ITA Nos

ITA 1443/BANG/2018[2008-09]Status: DisposedITAT Bangalore28 Oct 2022AY 2008-09

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1441 & 1442/Bang/2018 Assessment Year: 2009-10 & 2012-13 Acit Central Circle- M/S. Kansur Developers India Pvt. Ltd. 1(4) No.2650, Ground Floor Bengaluru Vs. 37Th B Cross, 28Th Main, 9Th Block Jayanagar Bangalore 560 009 Pan No : Aacck9866F Appellant Respondent C.O. Nos.103&104/Bang/2018 (Arising Out Of Ita Nos.1441 & 1442/Bang/2018) Assessment Years: 2009-10 & 2012-13

For Appellant: Shri Dilip, Junior Standing Counsel forFor Respondent: Dept

Section 147

does not Investment represent any investment, it is the assessee own money transferred from outside India a/c to Indian NRI A/c. Therefore, Unexplained Investment does not attracts. 69A: Unexplained The amount of Rs.78,04,58,374/- is the credit appearing in the Money capital account of the assessee. The money

Assistant Commissioner of Income Tax Central Circle - 1(4), Bengaluru vs. M/S Kansur Developers India Pvt. Ltd., Bengaluru

In the result, the revenue appeals in ITA Nos

ITA 1442/BANG/2018[2012-13]Status: DisposedITAT Bangalore28 Oct 2022AY 2012-13

For Appellant: Shri Dilip, Junior Standing Counsel forFor Respondent: Dept

Section 147

Assistant Commissioner of Income Tax Central Circle-1-(4), Bengaluru vs. M/S Kansur Developers India Pvt. Ltd., Bengaluru

In the result, the revenue appeals in ITA Nos

ITA 1441/BANG/2018[2009-10]Status: DisposedITAT Bangalore28 Oct 2022AY 2009-10

For Appellant: Shri Dilip, Junior Standing Counsel forFor Respondent: Dept

Section 147

Kusuma Cashews, Karkala vs. The Principal Commissioner of Income Tax, Central, Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 511/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Oct 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2017-18

For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 115BSection 132Section 133ASection 143(2)Section 143(3)Section 263Section 69

revenue to the extent of excess stock found during the course of survey amounting to Rs.50,00,000/-, which should be treated as unexplained investment under section 69 and same is to be taxed under section 115BBE of the Income tax Act, 1961 and no set off of loss shall ... Income tax (Central), Bengaluru, has failed to appreciate the fact that, the said excess stock has already been added to the income as unexplained investment, in the original assessment order passed under section 143(3), dated 11.12.2019 and hence, question of erroneous so far as it is prejudicial

Malan Jewellery (Firm), Chidambaram vs. ITO Ward 3, Cuddalore

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

ITA 667/CHNY/2018[2013-14]Status: DisposedITAT Chennai19 Oct 2022AY 2013-14

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 667/Chny/2018 िनधा"रण वष" / Assessment Year: 2013-14

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. T.M. Sugunthamala, Addl. CIT

Section 133ASection 143(3)

Subhangi, Partner. Net profit admitted in the return for AY 2012-13 and 2013-14 have also been considered. I therefore confirm the unexplained investment u/s. 69 of Rs. 1,53,55,897/-.” 8. The Ld. AR for the assessee submitted that the Ld. CIT(A) erred in confirming addition

Sri Santhosh Nagesh Jannu, Raichur vs. The Deputy Commissioner of Income Tax, Central Circle, Bellary

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

ITA 824/BANG/2022[2019-20]Status: DisposedITAT Bangalore19 Oct 2022AY 2019-20

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.S.V.Ravishankar, AdvocateFor Respondent: Sri.K.R.Narayana, Addl.CIT-DR

Section 115BSection 131(1)Section 133ASection 144Section 234Section 69B

appellant's case. 3. The learned CIT[A] is not justified in upholding the impugned addition of RS.1,31,80,644/- made as unexplained investment in stock of gold ornaments and silver articles by invoking the provisions of Section 69B of the Act while rejecting the appellant's additional business ... I.T.Act dated 26.02.2021, wherein the A.O. made solitary addition of Rs.1,31,80,644 u/s 69B of the I.T.Act as unexplained investment in excess stock of gold jewellery and silver articles. While doing so, the A.O. excluded the additional income of Rs.61,57,500 offered by the assessee