“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

Vulli Radhakrishna, Tuni vs. Income Tax Officer, Ward-1, Tuni

ITA 359/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.359/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Vulli Radhakrishna, Vs. Income Tax Officer, Tuni. Ward-1, Pan: Aegpv1751H Tuni. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 17/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short “A.O.”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short “The Act”) Dated 26/03/2022 For Assessment Year (Ay) 2015-16. 2 Vulli Radhakrishna Vs. Ito

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 147Section 148Section 151ASection 69A

deposits under section 69A of the Act: Rs. 28,82,633/-; (ii) addition of unexplained payment of credit cards bills: Rs.11,79,160/-; (iii) unexplained investment towards purchase of equity shares: Rs.3,76,565/-; and (iv) short term capital gains (STCG) on sale of equity shares: Rs.1

Karthik Kumar Kyatham, Nizamabad vs. ITO, Ward-1, Adilabad

ITA 1658/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1658/Hyd/2025

For Appellant: CA Phaneendra NagFor Respondent: B K Vishnu Priya, Sr. AR

Section 147Section 148Section 151ASection 24Section 249(3)Section 250Section 69

before the Assessing Officer. The Assessing Officer after considering the submissions of the assessee made additions on account of variations in respect of unexplained investment u/sec.69 of the Act amounting to Rs.2,62,000/-; variation in respect of income from house property amounting to Rs.30,675/-; variation in respect

G K Constructions.Co, Hyderabad vs. ITO, Ward-8(1), Hyderabad

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

ITA 1608/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Dec 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1608/Hyd/2025 Assessment Year 2017-2018 G K Constructions Co. The Income Tax Officer, Hyderabad – 500 050. Vs. Ward-8(1), Telangana. Hyderabad. Pan Aapfg7527F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca C. Maheshwar Reddy राज" व "ारा /Revenue By: G Saratha, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 26.11.2025 घोषणा की तारीख/Pronouncement: 19.12.2025 आदेश/Order

For Appellant: CA C. Maheshwar ReddyFor Respondent: G Saratha, Sr. AR

Section 143(3)Section 144Section 69

ought to have considered that there is no scope for making addition of Rs.2,74,31,960/- towards secured loans as unexplained investment since the Appellant has furnished the information before the Ld. CIT(A) which ought to have been adjudicated. 3 ITA.No.1608/Hyd./2025 ... each partner was clearly explained, and ought to have observed that there is no reason for the Ld. AO to treat the same as unexplained investment u/s 69. 9. The Ld. CIT(A) ought to have observed that the Appellant has submitted the sources and established the identity

Srinivas Chowdary Vallabhaneni, Secunderabad vs. DCIT., Central Circle-1(4), Hyderabad

ITA 1461/HYD/2025[2019-20]Status: DisposedITAT Hyderabad19 Dec 2025AY 2019-20

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1461/Hyd/2025 (निर्धारण वर्ष/Assessment Year: 2019-20)

For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Smt. Reema Yadav, Sr. DR

Section 115BSection 271Section 271ASection 274

Apart from the cash of Rs.7.00 lakhs found during the course of search; we find no other incriminating material has been found nor any unexplained investment or unexplained expenditure or unexplained asset were found. Under these circumstances, merely because the assessee has admitted total income of Rs.35.00 lakhs, which includes

Krishnakumar Manda, Medchal vs. DCIT., Circle-12(1), Hyderabad

ITA 1017/HYD/2025[2021-22]Status: DisposedITAT Hyderabad19 Dec 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos. 1016 & 1017/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2021-22) Shri Krishnakumar Manda, Vs. Deputy Commissioner Of Medchal Income Tax Pan:Bmspm9739D Circle 12(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Phaneendra Nag, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR

Section 144BSection 2Section 250Section 69

ought to appreciate the fact that Ld. AO has erred by making addition of 13,20,000 u/s 69 as Unexplained Investment. 9. The Ld. CIT(A) ought to appreciate the fact that the Assessee has purchased a house property for 66,00,000 out of which

Krishnakumar Manda, Medchal vs. DCIT., Circle-12(1), Hyderabad

ITA 1016/HYD/2025[2021-22]Status: DisposedITAT Hyderabad19 Dec 2025AY 2021-22

For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR

Section 144BSection 2Section 250Section 69

Jaydip Dhar, Jalpaiguri vs. ITO, Ward 1(1), Jalpaiguri

Appeal of the assessee is allowed

ITA 642/KOL/2025[2016-17]Status: DisposedITAT Kolkata19 Dec 2025AY 2016-17

Bench: Us That This Appeal Is Time Barred By 421 Days, For Which An Application Has Been Filed By The Assessee For Condoning Of The Said Delay. After Taking Into Account The Reasons Cited By The Ld Ar & Considering The Affidavit On Records We Find That The Delay Is Attributable To The Illness Of The Assessee For Which The Medical Certificate Along With Other Documents Were Placed Before Us

Section 143(2)Section 143(3)Section 250Section 56(2)(vii)Section 69BSection 69C

against the order of Ld. CIT(A) confirming the addition of Rs. 17,81,000/- as made by the AO as unexplained investment in respect of property u/s 69C of the Act without appreciating the fact that the said issue was not the subject matter of limited scrutiny ... assessee. Finally, the assessment was completed vide order dated 27.12.2018 passed u/s 143(3) of the Act by making three additions one unexplained investment of Rs. 17,81,000/-, two unexplained money u/s 69B, Rs. 10 lacs on account of cash deposit into bank and third the difference amount

Gitika Rani Majumder, Kolkata vs. ITO, Ward 49(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2156/KOL/2025[2016-2017]Status: DisposedITAT Kolkata19 Dec 2025AY 2016-2017

Bench: us that notice issued u/s 148 of the Act dated 31.03.2021 is barred by limitation as the same was served upon the assessee on 01.04.2021. The Ld. AR placed before the Bench, a copy of ITBA portal which showed that it was served on 01.04.2025 at 4.02 (Accountant Member)

Section 144BSection 147Section 148Section 148ASection 250Section 69

order dated 29.03.2022 by making an addition of Rs. 6,36,502/- to the income of the assessee u/s 69 of the Act as unexplained investment. The Ld. CIT(A) confirmed the assessment order. 5. The Ld. AR vehemently submitted before us that notice issued

Devisingh, Noida vs. ITO Ward-5(1)(2), Noida

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

ITA 3360/DEL/2025[2013-14]Status: DisposedITAT Delhi19 Dec 2025AY 2013-14

Bench: Shri C.N. Prasad & Shri Naveen Chandra[Assessment Year: 2013-14] Devi Singh Vs. Ito Ward- 5 (1) (2) Vill- Sorkha Sector-115, Noida Noida G.B. Nagar, 21301 Pan No.Apypd3604C Appellant Respondent Assessee By None Revenue By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 12.11.2025 Date Of Pronouncement 19.12.2025

Section 144Section 148Section 69

that the assessee has agitated the order of the Ld. CIT(A) in sustaining the addition of Rs.2,61,36,104/- in respect of unexplained investment. Inspite of issue of notice none appeared on behalf of the assessee nor any adjournment was sought. The appeal is disposed of on hearing

Suman Sangwan, Gurgaon vs. Income Tax Officer, National Faceless Assessment Centre

Appeal of the assessee is allowed

ITA 3497/DEL/2024[2017-18]Status: DisposedITAT Delhi19 Dec 2025AY 2017-18

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250Section 69Section 69A

before the AO. However, the submissions made by the assessee were not accepted and AO is treated the entire contribution of Rs.3.50 crores as unexplained investment of the assessee u/s 69A of the Act. 3. Against the said order, the assessee is in appeal before the Tribunal wherein the assessee ... submitted in Assessment/ Appellate Proceedings: - Lower Authorities have grossly erred in making/confirming addition of Rs.3,50,00,000/- under section 69 on account of unexplained investments without considering the facts of the case, submissions made by Assessee and documents produced by Assessee in assessment and appellate proceedings, therefore addition made

Deputy Commissioner of Income Tax, Central Circle-1, Noida vs. Raghav Bahl, Noida

In the result, appeal of the Revenue is dismissed

ITA 1640/DEL/2023[2020-21]Status: DisposedITAT Delhi19 Dec 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 139(1)Section 143(3)Section 250

furnish the required documentary evidences to justify the source of investment in the said property, the amount of Rs 26.45.38.040/- was treated as unexplained investment in property and added as deemed income u/s 69A of IT Act 1961 r.w.s. 115BBE of IT. Act 1961. 6.7 On the other hand

DCIT Central Circle-1, Noida vs. Raghav Bahl, Noida

In the result, appeal of the Revenue is dismissed

ITA 1639/DEL/2023[2012-13]Status: DisposedITAT Delhi19 Dec 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 139(1)Section 143(3)Section 250

Urusi Rahman, Kadma vs. ITO, Jamshedpur

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

ITA 257/RAN/2025[2017-18]Status: DisposedITAT Ranchi18 Dec 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.257/Ran/2025 Assessment Year: 2017-18 Urusi Rahman….... …………….…….…............................……….……Appellant 88 New Rani Kodar, Line No.4, Po Kadma, Jamshedpur, Jharkhand- 831005. [Pan: Amxpr0867K] Vs. Ito, Jsr…..……………….....….…..….........……........……...…..…..Respondent Appearances By: Shri Shrawan Kr. Jha, Adv., Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 27.05.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Did Not File Any Return Of Income For The Assessment Year 2017–18. Subsequently, The Case Was Reopened Under Section 147 Of The Income-Tax Act, 1961 On The Basis Of Information Received By The Assessing Officer That The Assessee Had Purchased An Immovable Property For A Declared Consideration Of ₹10,00,000, Whereas The Value Adopted For Stamp Duty Purposes Was ₹25,75,000. It Was Alleged That The Provisions Of Section 56(2)(Vii)(B) Of The Act Were Applicable. Accordingly, Notice Under Section 133(6) Was Issued Calling Upon The Assessee To Explain The Reasons For Not Filing The Return Of Income & To Furnish Details Regarding The Purchase Of The Property. However, There Was No Compliance By The Assessee. Thereafter, Notice Under Section 148 Of The Act Was Issued After Obtaining The Requisite Prior Approval From The Competent Authority. During The Course

Section 133(6)Section 147Section 148Section 250Section 56(2)(vii)Section 69

difference between the stamp duty value and the declared purchase consideration. Further, an addition of ₹11,64,575 was made on account of unexplained investment, including registration expenses, under section 69 of the Act, as the assessee failed to explain the source of investment in the immovable property with supporting

Kuruganti Srivalli, Hyderabad vs. ACIT Central Circle, Dhanbad

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

ITA 84/RAN/2024[2021-22]Status: DisposedITAT Ranchi18 Dec 2025AY 2021-22

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.84/Ran/2024 Assessment Year: 2021-22 Kuruganti Srivalli….. …………….…….…............................……….……Appellant S3 & S4 Vasudha Enclave, Vinayak Nagar, Neredmet, Hyderabad, Telengana-500056. [Pan: Asipk8246J] Vs. Acit, Central Circle, Dhanbad....….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ci(A)-3, Patna (Hereinafter Referred To As “Ld. Cit(A)”) Dated 23.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132(1) Of The Income-Tax Act, 1961 Was Conducted On The Premises Of The Atibir Group Of Cases. Simultaneously, Survey Proceedings Under Section 133A Of The Act Were Also Carried Out At Certain Business Premises Of The Group. In The Case Of The Assessee, Proceedings Were Initiated On 17.03.2021. The Assessee Filed Her Return Of Income Declaring Total Income Of ₹10,85,410. Thereafter, Notices Under Sections 143(2) & 142(1) Of The Act Were Duly Issued & Served. In Response, The Assessee Appeared & Filed Submissions During The Course Of Assessment Proceedings. During The Search, The Locker Maintained With Axis Bank Was Opened & Statements Of The Husband

Section 131Section 132(1)Section 133ASection 250

treated the value of 300 grams of gold amounting to ₹14,64,600 and 2000 grams of silver amounting to ₹1,46,000 as unexplained investment and added the same to the total income of the assessee. 3. Aggrieved, the assessee preferred appeal before

Jashvantlal Sakarchand Shah, Ahmedabad vs. The ITO, Ward-5(2)(2), Ahmedabad

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

ITA 1877/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice- & Ms Suchitra Kamblejashvantlal Sakarchand Shah, The Income Tax Officer, Vs. 1350, Khijdavalo Vas, Ward-5(2)(2), Mithakhali, Ahmedabad. Ahmedabad-380006. [Pan :Bkyps3918 N] (Appellant) .. (Respondent) Appellant By : Adjournment Application Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 16.12.2025 Date Of Pronouncement 18.12.2025

For Appellant: Adjournment ApplicationFor Respondent: Shri Abhijit, Sr. DR

Section 147Section 148Section 274Section 68

confirming the action of the Assessing Officer in making huge addition of Asst. Year : 2012-13 - 2– Rs.71,53,300/- is treated as unexplained investment u/s. 68 of the Income Tax Act, 1961. 3. On the facts and in the circumstances of the case as well

Jeetendra Laxmanbhai Patel, Ahmedabad vs. The ITO, Ward-6(1)(1), Ahmedabad

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

ITA 1758/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblejeetendra Laxmanbhai Patel, Income Tax Officer, Vs. 15/C, Sarda Shopping Centre, Ward-6(1)(1), Rabari Colony, Ahmedabad. Amraiwadi, Ahmedabad-380026. [Pan :Aocpp0793 B] (Appellant) .. (Respondent) Appellant By : Shri Parimalsinh B Parmar, Ar Respondent By: Shri Prateek Sharma, Sr. Dr Date Of Hearing 16.12.2025 Date Of Pronouncement 18.12.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- Delay Condoned This Appeal Is Filed By The Assessee Against The Appellate Order Dated 16.07.2024 Passed By The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, Relating To The Assessment Year 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Parimalsinh B Parmar, ARFor Respondent: Shri Prateek Sharma, Sr. DR

Section 115BSection 147Section 234ASection 250(6)Section 271(1)(c)Section 69

afforded several opportunities of hearing on 15.11.2022, 08.12.2023, 28.12.2023, 05.04.2024, 17.05.2024 and 01.07.2024 to furnish details, clarifications and explanations to substantiate the source of unexplained investment under section 69 of the Act. However, despite being granted multiple opportunities, the assessee remained non- compliant, sought adjournments, and failed to furnish ... also failed to submit any details or Jeetendra L Pate Vs. ITO Asst. Year : 2014-15 - 3– supporting evidence to establish the source of unexplained investment even before the Assessing Officer. During the course of hearing before us, the Ld. Counsel for the assessee prayed that, if one more opportunity

Pradeep Janardhan Sakhare, Sambhajinagar vs. ITO, Ward-1(A), Aurangabad

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

ITA 2509/PUN/2025[2018-19]Status: DisposedITAT Pune18 Dec 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2509/Pun/2025 धििाारण वर्ा / Assessment Year : 2018-19 Pradeep Janardhan Sakhare, Ito, Ward – 1(1), Ashay Regency, Flat No. 9, Aurangabad New Vishal Nagar, Chh. Sambhajinagar, Vs. Maharashtra-431001 Pan : Bobps8283M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Shubham N. Rathi (Virtual) Department By : Smt. Indira R. Adakil Date Of Hearing : 04-12-2025 Date Of 18-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 26.09.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2018-19. 2. Briefly Stated The Facts Are That The Assessee Is An Individual. For Ay 2018-19, The Assessee Filed His Return Of Income Declaring Income Of Rs.3,17,830/-. Based On The Information Received From The Insight Portal Under „High Risk Criu/Vru Information‟, It Was Found That The Assessee Has Done Transaction In Crypto Currency Of Rs.38,54,500/-, The Source Of Which Requires Verification & Also There Were Unexplained Credit Entries Aggregating To Rs.40,44,044/-. As The Assessee Failed To Disclose The Above Transaction In The Itr Filed For The Ay 2018-19, The Ld. Assessing Officer (“Ao”) Had Reason To Believe That The Above Income In Ay 2018-19 Has Escaped Assessment. Accordingly, The Case Of The Assessee Was Reopened U/S 147 By Issue Of Notice U/S 148 Of The Income Tax Act, 1961 (The “Act”) Dated 07.04.2022. In Response Thereto, The Assessee Filed His Return Of Income On 09.06.2023. Statutory Notice(S) U/S 142(1) & 144 Were Then Issued To The Assessee. As The Assessee Failed To File Any Compliance

For Appellant: Shri Shubham N. Rathi (Virtual)For Respondent: Smt. Indira R. Adakil

Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 151ASection 69ASection 69B

order dated 07.03.2024 passed u/s 147 r.w.s. 144 r.w.s. 144B of the Act thereby making an addition of Rs.38,54,500/- on account of unexplained investments in crypto currency u/s 69B and credit entries of RS.40,44,044/- as unexplained money u/s 69A of the Act, to the returned income ... erred in confirming the addition made of transaction in crypto currency amounting to ₹ 38,54,500/- as an unexplained investment u/s 69B. 3.2 The Ld. CIT(A) erred in making such addition without considering the fact that the investment amount is much lesser than the transaction and only net profit

Amar Kumar Agarwal, Kolkata vs. D.C.I.T., CC - 4(3), Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 2007/KOL/2025[2021-2022]Status: DisposedITAT Kolkata18 Dec 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

Section 132Section 153ASection 44ASection 69A

cash receipt from unverifiable sources. Therefore, it falls within the ambit of the Section 69B of the Act. Accordingly, the same was added as unexplained investment u/s 69B of the Act read with section 155BBE of the Act in the hands of the assessee. 9.2. In the appellate proceedings ... aggregating sum of Rs. 51,57,830/- and opined thatthese purchases were sourced from out of books/unexplained cash receipts and treated it as unexplained investment u/s 698 of the Act in the assessment order dated 30.03.2022 9.2.2. However, the assessee had contested in its submission that the jewelry was purchased

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1499/KOL/2025[2021-22]Status: DisposedITAT Kolkata18 Dec 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

Section 132Section 153ASection 44ASection 69A

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarawal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1498/KOL/2025[2020-21]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &

Section 132Section 153ASection 44ASection 69A