“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

Baldev Singh Bhadoriya, Gwalior vs. ITO-3(2), Gwalior

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

ITA 37/AGR/2023[2015-16]Status: DisposedITAT Agra04 Dec 2025AY 2015-16

Bench: Shri M. Balaganesh & Shri Sunil Kumar Singh(Through Virtual Hearing) Smt Kiran Lata Bhadoria, Vs. Income Tax Officer, Ward- L/H Of Late Shri Baldev 3(2), Singh Bhadoria, Gwalior Mig-20, Darpan Colony, 474005, Mp (Appellant) (Respondent) Pan: Ahopb3071D Assessee By : Shri Somil Agarwal, Adv Shri Deepesh Garg, Adv Revenue By: Shri Sukesh Kumar Jain, Cit(Dr) Date Of Hearing 15/09/2025 Date Of Pronouncement 04/12/2025

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri Sukesh Kumar Jain, CIT(DR)

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

land in assessment year 2013-14 was disbelieved by the Learned AO and accordingly an addition of Rs. 42,22,250/- was made as unexplained investment in the assessment. 6. With regard to another issue of difference in consideration by substituting the value fixed by the stamp valuation authorities

Asha Choudhury, Imphal vs. Income Tax Ward 1 Imphal, Imphal

ITA 303/GTY/2025[2016-2017]Status: DisposedITAT Guwahati04 Dec 2025AY 2016-2017

Bench: the date of hearing.”

Section 147Section 148Section 148ASection 151ASection 20Section 250Section 69

Learned Income Tax Officer, Ward-I-Imphal was not justify in making addition u/s.69 of Rs.60,00,000/- to my income on account of unexplained investment which was wrongly confirmed by the Commissioner of Income Tax (Appeals). 4. The Learned Income Tax Officer and the Commissioner of Income Tax (Appeals ... Imphal was not justify in I.T.A. Nos. 302 & 303/GTY/2025 Asha Choudhury making addition u/s.69 of Rs.60,00,000/- to my income on account of unexplained investment which was wrongly confirmed by the Commissioner of Income Tax (Appeals). 2. The Learned Income Tax Officer-Ward-I-Imphal wrongly started proceeding

Asha Choudhury, Imphal vs. Income Tax Officer Ward 1 Imphal, Imphal

ITA 302/GTY/2025[2015-2016]Status: DisposedITAT Guwahati04 Dec 2025AY 2015-2016

Bench: the date of hearing.”

Section 147Section 148Section 148ASection 151ASection 20Section 250Section 69

Mamta Patel, Raipur vs. ACIT, Circle-1(1), Raipur

In the result, appeal of the assessee is allowed

ITA 684/RPR/2025[2020-21]Status: DisposedITAT Raipur04 Dec 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.684/Rpr/2025 "नधा"रण वष" /Assessment Year : 2020-21 Mamta Patel E-802, Wallfort Height, Bhatagaon, Raipur-492 015 (C.G.) Pan: Ahrpp8532E

For Appellant: Mrs. Dimple Warylani, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 132(4)Section 69

wherein the Assessing Officer has erred in making addition of Rs.5,07,690/- under section 69 of the I.T. Act, 1961 on account of unexplained investment by holding that cash amount has been given for purchase of immovable property which is not recorded in the books of accounts. The addition ... Income Tax Act, 1961 and added the said amount of Rs.5,07,690/- to the total income of the appellant as an unexplained investment. I have carefully considered the written submissions of the appellant and have perused the assessment records, including the findings of the AO and the seized material

Ghanshyambhai Sutaria, Surat vs. ITO, Ward 3(2)(1), Surat

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

ITA 465/SRT/2025[2018-19]Status: DisposedITAT Surat04 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.465/Srt/2025 Assessment Year: (2018-19) (Hybrid Hearing) Ghanshyambhai Sutaria, Vs. Ito, 12 Kubernagar Katargam, Chorasi, Ward - 3(2)(1), Surat - 395004 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadhg8777M (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Abhishek Gautam, Sr. Dr Date Of Hearing 23/09/2025 Date Of Pronouncement 04/12/2025

Section 115BSection 147Section 148Section 250Section 69

making the addition of Rs.2,74,50,000/- u/s 69 of the Act on account of purchase of agricultural lands treating the same as unexplained investment. 5. On the facts and in the circumstances of the case as well as law on the subject, the learned AO has erred ... justify the source of investment with proper supporting documents. The purchase of Rs.2,74,50,000/- ITA No.465/SRT/2025/AY.18-19 Ghayshyambhai Sutaria was treated as unexplained investment u/s 69 of the Act and the entire amount was added to the total income. 4. Aggrieved by the order of AO, the assessee filed

Lila Verma, Malakhedi Road vs. ACIT/DCIT Itarsi, Aayakar Bhawan Itarsi

The appeal of the assessee is allowed for statistical

ITA 430/IND/2025[2012-13]Status: HeardITAT Indore04 Dec 2025AY 2012-13

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2012-13 Lila Verma Acit/Dcit Rewa Bhagwati Nagar

Section 143(3)Section 144Section 147Section 148Section 234Section 234ASection 246ASection 250Section 253

deemed short term capital gain was computed at Rs.15,06,370/-. Yet another addition of Rs.34,00,000/- was made on account of unexplained investment in the firm of M/s Nand Developers. That Page 2 of 7 Lila Verma A.Y. 2012-13 the aforesaid assessment order bears No:- ITBA/COM/F/17/2019-20/1021116220 ... account of deemed short term capital gain. 5. That the Ld. CIT(A) erred in confirming addition of Rs.34,00,000/- on account of unexplained investment in firm M/s Nand Developers. 6. That the Ld. CIT(A) erred in maintaining levy of interest u/s 234A

Mr. Pankaj Kisan Gorde, Kalyan vs. ITO, Ward 3(2), Kalyan

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

ITA 4662/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Dec 2025AY 2018-19

Bench: Shri Sandeep Gosain

Section 139(1)Section 143(1)Section 148Section 246ASection 250

dismissed in limine, it will lead to the levy of the taxes which are not due. 10. On merits, addition is on account of unexplained investments to the tune of Rs 10 Lakh arising out of the purchase of flat costing Rs 20 Lakh. Funding is provided my own father

Gurdeep Singh, Delhi vs. Manoj Kumar Assistant Commissioner of Income Tax, Central Circle -31, New Delhi

Appeal is allowed

ITA 5306/DEL/2025[2021-22]Status: DisposedITAT Delhi04 Dec 2025AY 2021-22

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Rajiv Kumar Jain, CAFor Respondent: Sh. Jitender Singh, CIT-DR

Section 143(3)Section 153C

appellate discussion. 4. Learned CIT-DR vehemently argues in this factual backdrop that the above search action had resulted in unearthing the assessee’s unexplained investment in cash which also stood duly collaborated by a whatsap chat between Sh. Parveen K. Jain and Sh. Vaibhav Jain. His case therefore

Sh. Vivek Gupta, Haryana vs. ACIT/DCIT, Haryana

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

ITA 5037/DEL/2025[2018-19]Status: DisposedITAT Delhi04 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2018-19] Shri Vivek Gupta Vs Acit/Dcit C-5/2A, Opp. C. C. Colony Central Circle Rana Pratap Bagh, North Delhi Karnal Delhi-110007 Pan-Aappg4029A Appellant Respondent Appellant By Shri Ved Jain, Adv. & Ms. Uma Upadhyay, Ca Respondent By Ms. Amisha S.Gupt, Cit Dr Date Of Hearing 04.12.2025 Date Of Pronouncement 04.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 29.07.2025 By Ld. Commissioner Of Income Tax (A)-3, Gurgaon [“Ld.Cit(A)”] In Appeal No.10453/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.12.2019 Passed U/S 143(3) R.W.S. 153B(1)(B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That A Search & Seizure Operation U/S 132 Were Carried Out At The Business Premises Of M/S. Oswal Group Of Cases, Karnal & Residential Premises Of Its Members On 22.01.2018. The Case Of The Assessee Was Also Covered U/S 132 Of The Act. Assessee Filed His Return Of Income On 28.07.2018 Declaring Total Income Of Inr 13,36,300/-. Thereafter, Statutory Notice U/S 143(2) Of The Act Was Issued On 23.04.2019 Followed By Notices U/S 142(1) Of The Act Alongwith Questionnaire Issued From Time To Time. In Response To Above, Assessee Filed Replies. Thereafter, The Ao Passed The Assessment Order U/S 143(3) R.W.S. 153B(1)(B) Of The Act Dated 29.12.2019 Assessing Total Income Of The Assessee At Inr 81,59,730/-.

Section 115BSection 132Section 142(1)Section 143(2)Section 143(3)Section 153DSection 250Section 69Section 69A

addition of Rs. 66,56,208/- made by the AO on account of jewellery found from the residence and locker treating the same as unexplained investment under section 69 read with section 115BBE of the Act. (ii) That the abovesaid addition has been confirmed without giving the benefit of CBDT

Income Tax Officer(Exemption), Ward-2(3), Guwahati vs. National Institute of Technology, Dimapur

Appeal of the Revenue is dismissed

ITA 188/GTY/2025[2019-20]Status: DisposedITAT Guwahati03 Dec 2025AY 2019-20

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

For Appellant: “6.2. As submitted by the appellant in the Grounds of appeal and the statement o

Section 10Section 148Section 250Section 69A

after which an addition of Rs. 33,00,00,000/- was made under Section 69A of the Act on account of alleged unexplained investment. A second addition was made of Rs. 1,17,567/- under the head income from ‘business and profession’. Aggrieved with this action, the assessee approached

Msl Fish Traders Private Limited, Bhubaneswar vs. Dy.CIT, Central Circle-2, Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 333/CTK/2025[2018-2019]Status: DisposedITAT Cuttack03 Dec 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.332 & 333/Ctk/2025 ("नधा"रण वष" / Assessment Years: 2017-18 & 2018-19) Msl Fish Traders Private Limited, Vs Dcit, Central Circle-2, Rooom No.14, Fish Market, Unit-4, Bhubaneswar. Bhubaneswar. Pan No. : Aajcm 1080 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri D.Parida, Ca & Shri Chitrasen Parida, Adv राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Ld Cit Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 3 /12/2025 आदेश / O R D E R Per Bench : These Are Appeals Filed By The Assessee Against The Separate Orders Dated 31.3.2025 Passed By Ld Cit(A), Bhubaneswar-2 In Appeal No.Cit(A), Bhubaneswar-2/11252/2017-18 For The Assessment Years 2017-18 & 2018-19, Respectively. 2. Shri D.Parida & Shri Chitrasen Parida, Ld Ars Appeared For The Assessee & Shri Ashim Kumar Chakraborty, Ld Cit Dr Appeared For The Revenue. 3. It Was Submitted By Ld Ar That The Assessee Has Filed Written Submission, Which Reads As Follows:

For Appellant: Shri D.Parida, CA and Shri ChitrasenFor Respondent: Shri Ashim Kumar Chakraborty, ld CIT

Section 132Section 153ASection 246ASection 250Section 69

assessed income of Rs.8,50,56,534/- vide order dated 20.05.2021. thereby making an addition of Rs.6,69,50,000/- on account of unexplained investment u/s 69 of the Act in respect of purchase of Bhusandpur land on the basis of notebook/diary found during the course of search and seizure ... dated 31.03.2025 vide DIN & Order No: ITBA/APL/S/250/2024-25/1075354490(1) u/s 250 of the Income Tax Act, 1961 with regard to confirming the addition of unexplained investment partially and commission income is excessive, arbitrary and bad in law. General in nature Grounds No.2: That the learned CIT (Appeals) has grossly erred both

Msl Fish Traders Private Limited, Bhubaneswar vs. Dy.CIT, Central Circle-2, Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 332/CTK/2025[2017-2018]Status: DisposedITAT Cuttack03 Dec 2025AY 2017-2018

For Appellant: Shri D.Parida, CA and Shri ChitrasenFor Respondent: Shri Ashim Kumar Chakraborty, ld CIT

Section 132Section 153ASection 246ASection 250Section 69

Prasanth Puttamareddy, Nellore vs. Income Tax Officer, Ward-1, Nellore

In the result, the appeal filed by the assessee in ITA

ITA 1555/HYD/2025[2016-17]Status: DisposedITAT Hyderabad03 Dec 2025AY 2016-17

Bench: the Ld. CIT(A).

Section 133(6)Section 147Section 148Section 194ISection 271(1)(c)Section 69

best-judgment assessment order under Section 147 r.w.s. 144 r.w.s. 144B of the Act and made an addition of Rs. 40,80,152/- as unexplained investment under Section 69 of the Income-tax Act. 4. Aggrieved with the assessment order, the assessee preferred appeal before

Prasanth Puttamareddy, Nellore vs. Income Tax Officer, Ward-1, Nellore

In the result, the appeal filed by the assessee in ITA

ITA 1554/HYD/2025[2016-17]Status: DisposedITAT Hyderabad03 Dec 2025AY 2016-17

Bench: the Ld. CIT(A).

Section 133(6)Section 147Section 148Section 194ISection 271(1)(c)Section 69

Maheshwar Reddy Kura, Hyderabad vs. Income Tax Officer, Ward-2, Karimnagar

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

ITA 1542/HYD/2025[2017-18]Status: DisposedITAT Hyderabad03 Dec 2025AY 2017-18

Bench: the Ld. CIT(A).

Section 115BSection 133(6)Section 144Section 147Section 148Section 250Section 270ASection 271ASection 272A(1)(d)Section 69

completed the assessment ex parte under Section 144 r.w.s. 147 and determined the total income at Rs.49,51,868/-, inter alia, making additions towards unexplained investment under Section 69 of the Act, estimated business income on undisclosed turnover, and unexplained cash deposits under Section 69 read with Section 115BBE ... Thereafter, the A.O. initiated penalty proceedings under Section 270A for misreporting and underreporting, under Section 271AAC(1) for unexplained investment, and under Section 272A(1)(d) for non-compliance with notices, and 3 Maheshwar Reddy Kura issued the final demand after charging interest under Sections 234A, 234B and 234C

Syed Mohammed Asad Ullah Hussaini, Hyderabad vs. ACIT, Central Circle-2(3), Hyderabad

Accordingly, the appeal filed by the assessee is dismissed

ITA 268/HYD/2024[2016-17]Status: DisposedITAT Hyderabad03 Dec 2025AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.268/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Syed Mohammed Asad Vs. Acit, Ullah Hussaini, Central Circle-2(3), Hyderabad. Hyderabad. Pan: Abfph0148G (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao राज" व "ारा/Revenue By: Shri Gurpreet Singh, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 13/10/2025 घोषणा की तारीख/Date Of 03/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Cit(Appeals)-12, Hyderabad, Dated 14.09.2023, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, ”Ao”) Under Section 143(3) R.W.S. 153C Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 28.03.2022, For The Assessment Year 2016- 17. The Assessee Has Assailed The Impugned Order Of The Cit(Appeals) On The Following Grounds Of Appeal Before Us.

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr.AR

Section 132Section 143(3)Section 153ASection 250Section 69

based on the above agreement becomes invalid.\ 11. The Ld. CIT(A) erred in upholding the addition of Rs. 25,00,000/- made towards unexplained investment u/s 69, without fairly appreciating the facts of the case. 3 Syed Mohammed Asad Ullah Hussaini vs ACIT 12. The Ld. CIT(A) erred ... lakhs, i.e., 1/5th of Rs. 1.75 crores (supra) as unexplained money under Section 69A of the Act; and (ii) Rs. 25 lakhs (supra) as unexplained investment under Section 69 of the Act. The assessee submitted that he had no knowledge of the seized documents and was not a party

Assistant Commissioner of Income Tax, Circle - Shillong, Shillong vs. Shri Chandra Mohan Jha, Shillong

Appeals are partly allowed

ITA 78/GTY/2018[2013-14]Status: DisposedITAT Guwahati02 Dec 2025AY 2013-14

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 69Section 69A

undisclosed investments u/s 69 of the Act. (v) Rs. 2,32,06,500/- again as unexplained investment u/s 69 of the Act. (vi) Rs. 41,25,000/- as unexplained cash deposit u/s 69A of the Act. 2.1 Aggrieved with this action, the Revenue (ITA No. 78/Gty/2018) has approached the ITAT ... facts and in the circumstances of the case, the Ld.CIT(A) erred in deleting an addition of Rs. 1,25,00,000/- as unexplained investments in Fixed Deposits u/s 69 of the IT Act. 6. Whether on the facts and in the circumstances of the case

Shri Chandra Mohan Jha, Shillong vs. Assistant Commissioner of Income Tax, Circle - Shillong, Shillong

Appeals are partly allowed

ITA 62/GTY/2018[2013-14]Status: DisposedITAT Guwahati02 Dec 2025AY 2013-14

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 69Section 69A

Assistant Commissioner of Income Tax, Circle-Shillong, Shillong vs. Smt. Indu Rani Jha, Shillong

Appeal is partly allowed for statistical purposes

ITA 298/GTY/2018[2013-14]Status: DisposedITAT Guwahati02 Dec 2025AY 2013-14

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 143(3)Section 250Section 69Section 69A

Whether on the facts and in the circumstances of the case, the Ld.CIT (A) erred in deleting addition of Rs.30,00,000/-as unexplained investments in Fixed Deposits u/s 69 of the IT Act. I.T.A. No. 298/GTY/2018 Smt. Indu Rani Jha 7. Whether in the facts and in the circumstances ... case, the Ld.CIT(A) erred in deleting an addition of Rs.30,50,000/- as unexplained investment in Immovable property u/s 69 of the IT Act. 8. For that the appellant craves leave to add, alter, amend any/all of the grounds of appeal before or during the course of hearing

Krishna Chandra Das, Twenty Four Parganas South vs. I.T.O., Ward - 25(1), Kolkata

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

ITA 1804/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Dec 2025AY 2019-2020

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2019-20 Krishna Chandra Das..……………..………………….……….……….……Appellant Ramkrishnanagar Laskarpur, Alipore, 24 Parganas (S), W.B - 743515. [Pan: Ajapd6700B] Vs. Ito, Ward-25(1), Kolkata………….…………………….....……...…..…..Respondent Appearances By: Shri B. B. Payra, Advocate, Appeared On Behalf Of The Appellant. Shri Dipu Koley, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 27, 2025 Date Of Pronouncing The Order : December 02, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 24.06.2025 Of The National Faceless Appeal Centre Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2019–20. 2. Brief Facts Of The Case Are That The Assessee Had Not Filed Original Return Of Income For The A.Y. 2019-20. In The Absence Of Voluntary Compliance, The Assessing Officer Initiated Reassessment Proceedings U/S 147 R.W.S. 144 Of The Act By Making Following Additions:

Section 142(1)Section 147Section 15Section 250Section 272A(1)(d)Section 45Section 56Section 69ASection 69B

Income from other sources u/s 56 amounting to Rs. 84,644/-. iii. Salary Received u/s 15 amounting to Rs. 34,64,292/-. iv. Unexplained Investment U/s 69B amounting to Rs.70,79,999/-. Krishna Chandra Das v. Unexplained Money U/s 69A amounting to Rs. 19,64,920/- 2.1 During the assessment