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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

Deputy Commissioner of Income -Tax, Central Circle-1(2), Ahmedabad vs. M/S Zen Industries Pvt. Ltd., Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 888/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2020-21

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Anil Kshatriya &For Respondent: Shri Sher Singh, CIT-DR &
Section 131Section 132Section 147Section 148

were used by the Assessing Officer to make substantive additions in the hands of the alleged purchaser, Shri Mustufamiyan Hussainmiya Shaikh, on account of unexplained investment in stock and estimated gross profit on alleged unaccounted purchases from Zen Group. In the appeals of the said purchaser

Vicky Agro Food Products & Suppliers Pvt Ltd, Mumbai vs. ITO WD-8(3)(3), Mumbai

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

ITA 9158/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Mar 2026AY 2012-13

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarvicky Agro Food Ito-8(3)(3), Products & Suppliers Room No. 616, 6Th Pvt. Ltd. Vs. Floor, Aayakar Bhavan, 125/129, Central M. K. Road, Warehousing Churchgate, Mumbai- Corporation Building 400020 Reay Road (East), Mumbai-400 033 Pan/Gir No. Aadcv3351K (Applicant) (Respondent) Assessee By Shri Kiran Mehta, Ld. Ar Revenue By Shri Nayanjyoti Nath, Ld. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 16.03.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

amount as unexplained cash credit under section 68 of the Act. 5 Vicky Agro Food Products & Suppliers Pvt. Ltd. (iii) Addition on account of unexplained investment - The Assessing Officer also observed that the assessee had made payments for acquisition of a property situated at Plot No. D-70, MIDC Industrial ... payment of only Rs. 1,88,00,000/-. The difference amount of Rs. 1,30,00,000/- was treated by the Assessing Officer as unexplained investment under section 69 of the Act. Accordingly, the Assessing Officer determined the total income of the assessee

Akshit Mahesh Karia, Mumbai vs. ITO Ward 3(2), Mumbai

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

ITA 6052/MUM/2025[2015-16]Status: DisposedITAT Mumbai16 Mar 2026AY 2015-16

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: NoneFor Respondent: Shri Surendra Mohan, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)Section 274

made addition of Rs.18,25,000/- towards the Long Term Capital Gain (“LTCG” for short) out of sale of immovable property, unexplained investment u/s 69 amounting to Rs.23,75,000/- and undisclosed commission receipt amounting to Rs.15,000/- thereby determining the total income at Rs.50,70,560/-. The assessment order

Monaliza Nongrum, Shillong vs. Assessing Officer, Shillong

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

ITA 427/GTY/2025[2018-19]Status: DisposedITAT Guwahati13 Mar 2026AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am**

Section 10Section 69A

Income-tax Act, 1961 (the Act) towards, money deposited in the bank account and ₹10 lacs u/s 69A of the Act as unexplained investment. At the outset, the ld. Counsel for the assessee submitted that the assessee is a bona fide resident of Meghalaya and has been engaged

Veera Reddy Posham, Nalgonda vs. ACIT, Central Circle1(1), Hyderabad

In the result, ITA.No.1830/Hyd

ITA 1830/HYD/2025[2022-23]Status: DisposedITAT Hyderabad13 Mar 2026AY 2022-23

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.Nos.1829 & 1830/Hyd/2025 Assessment Years 2020-2021 & 2022-2023 Veera Reddy Posham, The Acit, Nalgonda – 508 246 Central Circle-1(1), Vs. Telangana. Hyderabad. Telangana. Pan Aijpp0376P (Applicant) (Respondent) -None- िनधा"रती "ारा/Assessee By : राज" व "ारा/Revenue By : Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 09.03.2026 घोषणा की तारीख/Pronouncement: 13.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 132Section 143(3)Section 147Section 148Section 234FSection 250(6)Section 270ASection 80CSection 80C(2)(xvii)

another group (IRA Group) and there was no independent tangible material in the case of the Appellant. B. Ground on Addition u/s 69 - Unexplained Investment Rs.35,00,000/-  The Learned CIT(A) erred in confirming the addition of Rs.35,00,000/- u/s 69 of the Act without any direct, corroborative ... reasoned adjudication, rendering it unsustainable in law. F. Without Prejudice  Without prejudice to the above grounds, the addition of Rs.35,00,000/- made as unexplained investment u/s 69 and taxed u/s 115BBE is highly excessive and arbitrary, and ought to be deleted or substantially reduced. General Ground The Appellant craves

Veera Reddy Posham, Nalgonda vs. ACIT, Central Circle-1(1), Hyderabad

ITA 1829/HYD/2025[2020-21]Status: DisposedITAT Hyderabad13 Mar 2026AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita.Nos.1829 & 1830/Hyd/2025

For Appellant: -None-For Respondent: Dr. Sachin Kumar, Sr. AR
Section 10Section 132Section 143(3)Section 147Section 148Section 234FSection 250(6)Section 270ASection 80CSection 80C(2)(xvii)

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Mahmood Hussain Syed, Hyderabad vs. Assistant Commissioner of Income Tax, Circle-6(1), Hyderabad

ITA 541/HYD/2023[2014-15]Status: DisposedITAT Hyderabad13 Mar 2026AY 2014-15

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 143(3)Section 50CSection 56(2)Section 56(2)(vii)

read as under : “1. The learned AO has erred in facts and law while e passing the assessment order u/s 143(3). 2. 69 Unexplained Investment: The learned AO erred in adding Rs. 2,37,92,4 44/-as unexplained investment ignoring the fact that the mismatch in capital account ... ground No.1 of assessee’s appeal is addition of Rs. 2,37,92,244/- under Section 69A of the Income-tax Act, 1961, as unexplained investment towards difference in capital account of the proprietor. The facts with regard to the impugned dispute are that, during the course of assessment

DCIT, Circle 2(1), Trichy Stationed at Thanjavur, Thanjavur vs. Sri Bhuvanesvari Thangamaligai, Pudukkottai

In the result, appeal filed by the Revenue is dismissed

ITA 2915/CHNY/2025[2017-18]Status: DisposedITAT Chennai13 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Respondent: Ms.R. Anitha, Addl.CIT
Section 133ASection 68

provisions of Section 69 & u/s.69 or 69A of the Act. Because, the mandate of the provisions of Section 69 & 69A of the Act, i.e., unexplained investments and unexplained money etc., may be deemed to be the income of the assessee for the financial year relevant to assessment year concerned ... nature and source of investment, then the question of making addition towards ITA No.2915/Chny/2025 & CO No.90/Chny/2025 (AY 2017-18) Sri Bhuvanesvari Jewellery :: 6 :: unexplained investment u/s. 69 of the Act does not arise. In this case, the source of deposits has not been disputed and has been created

Deputy Commissioner of Income Tax, Salem vs. Ravishankar, Salem

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

ITA 2626/CHNY/2025[2019]Status: DisposedITAT Chennai13 Mar 2026

Bench: Shri S.S. Viswanethra Ravi & Ms. Padmavathy, S.आयकर अपील सं./I.T.A. No.2626/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 The Deputy Commissioner Of Vs. Ravishankar, Income Tax, 735, Lrc Abarana Maaligai, Circle 1, Bazaar Street, Attur Tk, Salem. Salem 636 102. [Pan: Aahhr5519N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shiva Srinivas, Cit ""थ" की ओर से/Respondent By : Shri D. Anand, Advocate सुनवाई की तारीख/ Date Of Hearing : 24.02.2026 घोषणा की तारीख /Date Of Pronouncement : 13.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 21.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai For The Assessment Year 2019-20. 2. We Find That This Appeal Is Filed With A Delay Of 55 Days. The Dcit Circle 1, Salem Filed A Condonation Petition For The Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Dcit Are Bonafide, Which 2

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri D. Anand, Advocate
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 69ASection 69B

finding excess stock at 3 I.T.A. No.2626/Chny/25 the time of survey and the addition made under section 69B of the Act as unexplained investment is not justified and directed the Assessing Officer to treat the same as business income vide para 6.8 of the impugned order. Having aggrieved, the Revenue ... difference in valuation of stock was out of finding of excess stock at the time of survey and the same cannot be treated as unexplained investment. He submits that the order of the ld. CIT(A) in directing the Assessing Officer to consider addition made under section

Mr. Shridhar Gangaram Anumandala, Mumbai vs. ITO Ward 22(3)(6), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 8391/MUM/2025[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI JAGADISH (Accountant Member)

For Appellant: NoneFor Respondent: Shri S. Anbuselvan (Sr. DR)
Section 139(1)Section 143Section 143(3)Section 234ASection 234BSection 250Section 50Section 55ASection 56(2)(x)Section 69

submission made with the appeal papers Bank Loan statement for purchase of flat as the Id. A.O. erred in making addition on account of unexplained investment u/s.69 of 1.T.Act, 1961 Rs.1,17,61,180/- being difference out of total payment made to purchase the residential flat vide Agreement for sale ... property for Rs. 1,55,00,000/- Less TDS Rs.1,55,000/-) being the money lying with the assesse and the balance is undisclosed / unexplained investment which is fully unjustified. The appellant appealed before the CIT (A), (NFAC that the Id. A.O. further erred in not giving / granting a chance

Bishnupriya Bijaychandra Mahanty, Navi Mumbai vs. Income Tax Officer, Mumbai

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

ITA 4477/MUM/2025[2018-2019]Status: DisposedITAT Mumbai13 Mar 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19 Bishnupriya Bijaychandra Mahanty Ito, Ward 28(1)(1), Mumbai 204 Plot 13/A Wing Siddhivinayak It-Office, Vashi Railway Vs. Chs, Sector 6, Ghansoli, Navi Station Building, Mumbai 400701, Navi Mumbai- 400703 Authroised Person Add: 218, Ratna High Street, Naranpura, Ahmedabad- 380013 Pan No. Btdpm 7308 A Appellant Respondent

For Respondent: Mr. Pritesh L. Shah (Virtually
Section 1Section 148Section 148ASection 149Section 69

facts and in law in upholding the addition of ₹1,21,00,254/- under Section 69 of the Income Tax 1 Act, 1961 as unexplained investment, without appreciating that the said amount was jointly Bishnupriya Bijaychandra Mahanty Bishnupriya Bijaychandra Mahanty 2 invested by the appellant along with her husband ... under Section 69 of the Income Tax Act, 1961, under Section 69 of the Income Tax Act, 1961, treating the same as unexplained investment, without appreciating treating the same as unexplained investment, without appreciating treating the same as unexplained investment, without appreciating that the said amount repr that the said

Krish Packaging Pvt Ltd, New Delhi vs. DCIT Central Circle, Noida

ITA 3942/DEL/2019[2011-12]Status: DisposedITAT Delhi13 Mar 2026AY 2011-12

Bench: Shri Anubhav Sharma & Shri Naveen Chandrakrish Packaging Pvt. Ltd. Vs. Dcit, Central Circle F-11, Basement Green Sector -33, Noida Park, Extension , Uttar Pradesh – 201307 New Delhi – 110016 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacck8980A Appellant .. Respondent

For Appellant: Sh. Salil Aggarwal, Sr. AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT
Section 143(3)Section 153CSection 69

which assessee had filed return showing of nil income and assessment was completed by making additions of Rs.95,60,000/- on account of unexplained investment u/s 69 of the Act on the basis of seized material which has been sustained by the ld. First Appellate Authority for which assessee

Vaneet Aggarwal, New Delhi vs. ACIT, Circle-14(2), New Delhi

In the result, appeal of the Assessee is dismissed

ITA 2607/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 10(38)Section 143(1)Section 143(2)Section 69ASection 69C

ITA No. 2607/Del/2019 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F': NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT

DCIT, Central Circle 1, Rajkot vs. Yagnik Road Highstreet LLP, Rajkot

Appeal of the revenue is dismissed:

ITA 684/RJT/2024[2021-22]Status: DisposedITAT Rajkot12 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 511 To 513/Rjt/2024 निर्धारणवर्ष /Assessment Year: 2020-21 To 2022-23 (Hybrid Hearing) Yagnik Road Highstreet Llp Vs. The Deputy Commissioner Of Office No.102, Ornament Arcade, Darbargadh Chowk, Bedinaka Road, Rajkot Rajkot-360001 Income Tax, Central-1 Income Tax Office, Amruta Estate Building, Near Girnar Cinema, Mg Road, Rajkot Rajkot-360001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfy4924F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं/.Ita No. 684/Rjt/2024 निर्धारणवर्ष / Assessment Year: 2021-22 (Hybrid Hearing) The Deputy Commissioner Of Vs. Yagnik Road Highstreet Llp Income Tax, Central-1 Income Tax Office, Amruta Estate Building, Near Girnar Cinema, M G Road, Rajkot Rajkot-360001 Office No.102, Ornament Arcade, Darbargadh Chowk, Bedinaka Road, Rajkot Rajkot-360001 स्थायी लेखासं./जी आइआरसं./Pan/Gir No.: Aacfy4924F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit(Dr) सुनवाई की तारीख/Date Of Hearing : 20/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/03/2026 Order

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 143(3)Section 147

when an addition is made on account of unaccounted income, then the benefit of telescoping of the said amount should given against addition of unexplained investment. 11. Another point for consideration is whether tangibleto additions pertaining to earlier years and current year have the same concrete existence to be telescoping ... Singh J. Juneja (2008) 302 ITR (63) (Guj) has held that In absence of any material on record to show that there was any unexplained investment made by the assessee which was reflected by the alleged unaccounted sales, the finding of the Tribunal that only the GP on the said

Yagnik Road Highstreet LLP, Rajkot vs. The Deputy Commissioner of Income Tax, Central -1, Rajkot

Appeal of the revenue is dismissed:

ITA 512/RJT/2024[2021-22]Status: DisposedITAT Rajkot12 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 511 To 513/Rjt/2024 निर्धारणवर्ष /Assessment Year: 2020-21 To 2022-23 (Hybrid Hearing)

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 143(3)Section 147

addition is made on account of unaccounted income, then the benefit of telescoping of the said amount should be given against addition of unexplained investment. 11. Another point for consideration is whether tangible additions pertaining to earlier years and current year have the same concrete existence to be telescoped against ... Singh J. Juneja (2008) 302 ITR (63) (Guj) has held that In absence of any material on record to show that there was any unexplained investment made by the assessee which was reflected by the alleged unaccounted sales, the finding of the Tribunal that only the GP on the said

Yagnik Road Highstreet LLP, Rajkot vs. Deputy Commissioner of Income Tax, Central -1, Rajkot

Appeal of the revenue is dismissed:

ITA 511/RJT/2024[2020-21]Status: DisposedITAT Rajkot12 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 511 To 513/Rjt/2024 निर्धारणवर्ष /Assessment Year: 2020-21 To 2022-23 (Hybrid Hearing) Yagnik Road Highstreet Llp Vs. The Deputy Commissioner Of Office No.102, Ornament Arcade, Darbargadh Chowk, Bedinaka Road, Rajkot Rajkot-360001 Income Tax, Central-1 Income Tax Office, Amruta Estate Building, Near Girnar Cinema, Mg Road, Rajkot Rajkot-360001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfy4924F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं/.Ita No. 684/Rjt/2024 निर्धारणवर्ष / Assessment Year: 2021-22 (Hybrid Hearing) The Deputy Commissioner Of Vs. Yagnik Road Highstreet Llp Income Tax, Central-1 Income Tax Office, Amruta Estate Building, Near Girnar Cinema, M G Road, Rajkot Rajkot-360001 Office No.102, Ornament Arcade, Darbargadh Chowk, Bedinaka Road, Rajkot Rajkot-360001 स्थायी लेखासं./जी आइआरसं./Pan/Gir No.: Aacfy4924F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit(Dr) सुनवाई की तारीख/Date Of Hearing : 20/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/03/2026 Order

For Appellant: Shri D.M. Rindani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 132Section 143(3)Section 147

when an addition is made on account of unaccounted income, then the benefit of telescoping of the said amount should given against addition of unexplained investment. 11. Another point for consideration is whether tangible additions pertaining to earlier years and current year have the same concrete existence to be telescoped ... Singh J. Juneja (2008) 302 ITR (63) (Guj) has held that In absence of any material on record to show that there was any unexplained investment made by the assessee which was reflected by the alleged unaccounted sales, the finding of the Tribunal that only the GP on the said

Ajitbhai Bhimabhai Bharwad, Ahmedabad vs. The ITO, Ward-3(1)(1), Ahmedabad

The appeal of the assessee is allowed for statistical purposes

ITA 2609/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2022-23

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Tej Shah, A.RFor Respondent: Shri C Dharani Nath, Sr. DR
Section 271ASection 68Section 69Section 69A

documentary evidence such as cash book or proof of availability of funds. Accordingly, the Assessing Officer treated the amount of ₹39,60,750/- as unexplained investment under section 69 of the Act and added the same to the income of the assessee. The Assessing Officer further observed that the assessee ... valuable judicial time. 8. At the same time, considering the fact that the impugned additions involve substantial amounts and the issues relating to unexplained investment and unexplained cash deposits require proper examination on the basis of documentary evidence, we are of the considered view that the matter deserves

Suman Nilakanth Masal, Ahemdnagar vs. ITO Ward-2, Ahmednagar

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

ITA 2279/PUN/2025[2018-19]Status: DisposedITAT Pune12 Mar 2026AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2018-19 Suman Nilakanth Masal Ito, Ward – 2, 983, Masal Colony, Rashin Karji, Vs. Ahmednagar Ahmednagar – 414403 Pan: Bvrpm6017J (Appellant) (Respondent) Assessee By : Shri Pramod S Shingte Department By : Shri Amit Bobde, Cit Date Of Hearing : 11-03-2026 Date Of Pronouncement : 12-03-2026

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Amit Bobde, CIT
Section 147Section 148Section 270ASection 69

assessee at Rs.87,56,480/- by treating Rs.53,60,000/- as short term capital gain and treating the time deposits of Rs.33 lakhs as unexplained investment u/s 69 of the Act. The Assessing Officer thereafter initiated penalty proceedings u/s 270A of the Act for under-reporting the income in consequence

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1594/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh12 Mar 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1232/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1594/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2021-22) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars Revenue By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 12.03.2026 : आदेश / O R D E R Per Bench

For Appellant: Sh. Sudhir Sehgal (Advocate) and Sh. Sahil RatraFor Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl
Section 115BSection 143(3)Section 65BSection 69C

erred in not appreciating the fact that the amount of Rs.20,59,380/- & Rs.1,29,35,806/- income from unexplained investment in stock during the AY 2021-22 was to be considered as unrecorded business income u/s 69A of the Income Tax Act. 1.4 The Ld. AR advanced arguments ... basis of loose papers unless the same is corroborated by cogent evidences. It could be seen that no evidence of excess cash or unexplained investment by the assessee has been found during search proceedings since the only addition made is addition of alleged unaccounted sales. Therefore, the addition made

Assistant Commissioner of Income Tax, Chandigarh vs. Saraf the Jewellers, Punjab

Appeal stand dismissed

ITA 1593/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh12 Mar 2026AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं. / Ita No.1231/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Saraf The Jeweller Dcit / Acit (Central)-2 बनाम/ Sco 45, Pocket No.1 C.R. Building Nac Showroom, Manimajra Himalaya Marg, Vs. Chandigarh – 160101 Sector-17E, Chandigarh "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं. / Ita No.1593/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) Dcit / Acit (Central)-2 Saraf The Jeweller बनाम/ C.R. Building Sco 45, Pocket No.1 Himalaya Marg, Nac Showroom, Manimajra Vs. Sector-17E, Chandigarh Chandigarh – 160101 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adafs-2345-B (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant Sh. Sudhir Sehgal (Advocate) & Sh. Sahil Ratra (Advocate) – Ld. Ars By : ""थ"कीओरसे/Respondent By : Sh. Abhishek Pal Garg (Cit) & Dr. Ranjit Kaur (Addl. Cit) – Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 12.02.2026 घोषणाकीतारीख /Date Of Pronouncement 11.03.2026 : आदेश / O R D E R Per Bench

For Respondent: Sh. Abhishek Pal Garg (CIT) & Dr. Ranjit Kaur (Addl. CIT) –
Section 115BSection 153A(1)(b)Section 153DSection 65BSection 68Section 69C

basis of loose papers unless the same is corroborated by cogent evidences. It could be seen that no evidence of excess cash or unexplained investment by the assessee has been found during search proceedings since the only addition made is addition of alleged unaccounted sales. Therefore, the addition made