“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

Krypton Distributors LLP (Earlier Known As Krypton Distributors Pvt. Ltd., Kolkata vs. ITO, Ward 12(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1733/KOL/2025[2013-2014]Status: DisposedITAT Kolkata02 Dec 2025AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Krypton Distributors Llp (Earlier Known As Krypton Ito, Ward 12(1), Distributors P. Ltd.) Aaykar Bhawan, P-7, Flat No.1A, 1, Abdul Rasul Chowringhee Square, Vs. Avenue, Kalighat, Kolkata-700069, West Bengal Kolkata-700026, West Bengal (Appellant) (Respondent) Pan No. Aadck5298G Assessee By : Shri Manoj Katuruka, Ar Revenue By : Shri Pankaj Pandey, Dr Date Of Hearing: 13.11.2025 Date Of Pronouncement: 02.12.2025

For Appellant: Shri Manoj Katuruka, ARFor Respondent: Shri Pankaj Pandey, DR

Section 139(1)Section 147Section 148Section 68

that the pressure of search was built so much that he had to make the surrender without having actual possession of the assets or unexplained investments or expenses incurred and that there was no such income as undisclosed. The Hon’ble Delhi High Court, after considering the fact and circumstances

P.N. Pandian, Chennai vs. ACIT, Central Circle-3(2), Chennai

In the result all the three appeals of the assessee are allowed

ITA 1145/CHNY/2025[2018-19]Status: DisposedITAT Chennai02 Dec 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:1143 To 1145/Chny/2025 िनधा$रण वष$ / Assessment Years: 2014-15, 2017-18 & 2018-19 P. N. Pandian, Acit, No.11/1, Mosque Colony, Vs. Central Circle -3(2), 13Th Street, Maduvankarai, Chennai. Guindy, Chennai – 600 032. [Pan: Ahppp-9266-M] (अपीलाथ"/Appellant) (&'थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. N.Arjun Raj, Advocate &'थ" की ओर से/Respondent By : Shri. Bipin. C.N., C.I.T. सुनवाई की तारीख/Date Of Hearing : 24.09.2025 घोषणा की तारीख/Date Of Pronouncement : 02.12.2025 आदेश /O R D E R Per S.R.Raghunatha, Am : The Present Appeals Are Filed Against The Order Of Learned Commissioner Of Income Tax (Appeals) - 18, Chennai, (In Short ‘Ld.Cit(A)’) For The Assessment Year (A.Y.) 2014-15 & 2017-18 Both Dated 04.03.2021 & 2018-19 Dated 14.12.2020. Since Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Filed By The Assessee Are Heard Together & Disposed Of By This Consolidated Order.

For Appellant: Shri. N.Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T

Section 153ASection 69

premises of the appellant valuing at Rs.10,79,853/- out of the total jewellery seized (865 grams) valuing at Rs. 25,59,109/-as unexplained investment in terms of Section 69 of the Act in the computation of taxable total income without assigning proper reasons and justification ... assessee, taking into consideration had estimated that the 500 grams of jewellery stood explained and the balance was to be sustained as unexplained investment in the hands of the assessee herein. 19. The assessee being aggrieved by the order of the Ld.CIT(A) for all three assessment years, had filed

P.N. Pandian, Chennai vs. ACIT, Central Circle-3(2), Chennai

In the result all the three appeals of the assessee are allowed

ITA 1144/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Dec 2025AY 2017-18

For Appellant: Shri. N.Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T

Section 153ASection 69

P.N. Pandian, Chennai vs. ACIT, Central Circle-3(2), Chennai

In the result all the three appeals of the assessee are allowed

ITA 1143/CHNY/2025[2014-15]Status: DisposedITAT Chennai02 Dec 2025AY 2014-15

For Appellant: Shri. N.Arjun Raj, AdvocateFor Respondent: Shri. Bipin. C.N., C.I.T

Section 153ASection 69

Piyush Sharma, Mumbai vs. Income Tax Officer Ward 20(2)(1), Mumbai

In the result, appeal of the Revenue is partly allowed for statistical purpose

ITA 6256/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri. Raj Kumar Chauhanpiyush Sharma Vs. Ito Ward-20(2)(1) A-1 Apartment, 8Th Floor, Flat No. 87, Piramal Chamber, Lalbaug, Malabar Hills, Mumbai-400 006 Mumbai-400 012 Pan: Aapps2589H (Appellant) (Respondent)

Section 132Section 142(1)Section 144Section 148Section 148ASection 250Section 69

said company. The assessee stated that she was the co-owner in the said property accordingly AO added Rs. 50,35,200/- as unexplained investments. It is stated that the said reassessment is merely passed on presumptions, assumption, conjectures, suspicious and on surmises on the basis of a dump pieces ... seized documents in search detailing cash received over and above agreement values and assessee has failed to produce credible evidence negating the source of unexplained investment. 4. Aggrieved by the impugned order, the assessee is in appeal before us and has raised the following grounds of appeal:- Piyush Sharma

Ajaydas Ukey, Mumbai vs. Income-Tax Officer, Ward-1(1)(1) Mumbai, Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 5759/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Surendra Mohan, Sr. DR

Section 142(1)Section 144Section 147Section 148Section 250Section 271(1)(b)

Since the assessee did not respond to the statutory notices issued by the AO, the AO treated the amount of the property purchased as unexplained investment and added to the income of the assessee accordingly. The AO also added the difference between the salary income as per Form 26AS

Subramanian Bashkaran, Chennai vs. ITO, Non Corporate Ward 10(6), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2538/CHNY/2025[2016-17]Status: DisposedITAT Chennai01 Dec 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: 19.11.2025

Section 133(6)Section 144BSection 147Section 148Section 148ASection 151ASection 69

Officer, Non-Corp Ward-10(6), Chennai dated 25.03.2024 u/s.147 r.w.s 144 of the Act by making an addition of Rs.3,96,347/- as unexplained investment u/s.69 of the Act. Aggrieved by the order of the AO, the assessee filed appeal before the ld.CIT(A) and the ld.CIT

ACIT, Chennai vs. Sri Balaji Educational Amd Trust Charitable Public Trust, Chenna

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1471/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

nature and source of cash deposits of Rs. 5,31,39,642/- into the bank account of the assessee, the same is treated as unexplained investment u/s 69 of the Income Tax Act 1961 and treated as income of the assessee and brought to tax accordingly.” 8. The ld.CIT ... deposited, rejecting the claim of the assessee in an incongruous and unscientific manner, this addition of Rs.5.31 crores was made treating the deposit as unexplained investment to be brought to tax u/s.69 r.w.s. 115BBE of the Act. 21.7 The Ld.DR had contested the argument of the Ld.AR and insisted that

M/S. Sri Balaji Educational and Charitable Public Trust, Chennai vs. ACIT, Central Circle-3(4), Chennai

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1249/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

Bhagirathi Krishnan, New Delhi vs. ITO Ward 35(5), New Delhi

ITA 6847/DEL/2025[2016-17]Status: DisposedITAT Delhi01 Dec 2025AY 2016-17

Bench: Shri Pawan Singh(Physical Hearing) Bhagirathi Krishnan, Income Tax Officer, Ward-35(5), C/O-Anil Jain Dd & Co. 611, 6Th Floor, Vs Civic Centre, Surya Kiran Building, 19- K.G. Marg, New Delhi-110002 New Delhi-110001 Pan:Aqzpk1479J Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 254(1)Section 271(1)(c)Section 69

income of Rs.1,60,382/-. The assessment was completed on 09.02.2024 in making addition of Rs.7,25,000/- under section 69 on account of unexplained investment and Rs.93,287/- on account of other credit in the bank account. Before the learned CIT(A), the assessee made similar submissions as explained

Anurodh Sahu, Jabalpur vs. ITO (It and Tp), Bhopal

In the result, the appeal is allowed for statistical purposes

ITA 11/JAB/2024[2018-19]Status: DisposedITAT Jabalpur28 Nov 2025AY 2018-19

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

For Appellant: Sh. Anil Agrawal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR

Section 147Section 148Section 271

during the financial year 2017-18 and since only Rs. 11 Lacs of these purchases had been explained, the remainder was unexplained investment under section 69 which deserved to be confirmed. 6 Anurodh Sahu A.Y. 2018-19 6. We have duly considered the facts and circumstances of the case

Rajendra Sahu, Katni vs. Income Tax Officer-1, Katni

ITA 162/JAB/2023[2013-14]Status: DisposedITAT Jabalpur28 Nov 2025AY 2013-14

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2013-14 Rajendra Sahu, Vs. Income Tax Officer-1, Ram Manohar Lohiya Ward No. 4, Behind Katni Durga Hospital, Adarsh Colony, Katni Pan: Auvps4330A (Appellant) (Respondent) Assessee By: Sh. Rahul Bardia, C.A. Revenue By: Sh. N.M. Prasad, Sr. Dr 1 Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 20.10.2023 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Orders Passed By The Assessing Officer Under Section 147 R.W.S. 144B Of The Income Tax Act On 27.03.2022. The Grounds Of Appeal Are As Under:- “(1) The Order Passed By The Ld Cit (A) Is Bad In Law & Facts, Void Ab Initio & Without Jurisdiction. (2) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When Notice Issued U/S 148 Is Defective. There Is No Application Of Mind Of Ld Ao & Also Of Sanctioning Authority. (3) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When Assessee Made Specific Request To Share Copies Of All The Statement Recorded By The Investigation Wing Regarding The Sale Of Properties. These Copies Were Not Given Inspite Of Using Them Against The Assessee. (4) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Order, When The Hon'Ble Tribunal For Benami Transactions Has Released The Property & Given Relief To Alleged Benamidar & Alleged Beneficial Owner. Copy Of Order Was Filed On Record. (5) The Ld Cit (A) Erred In Law & Facts Of The Case In Sustaining The Addition Of Rs 88,52,740/-U/S 69. 1 A.Y. 2013-14 Rajendra Sahu (6) The Appellant Reserves The Right To Add, Amend Or Alter Any Grounds Of Appeal.”

For Appellant: Sh. Rahul Bardia, C.AFor Respondent: Sh. N.M. Prasad, Sr. DR 1

Section 131Section 147Section 148Section 69

assessee and held that the payment of Rs. 88,52,740/- in the F.Y. 2012-13, relevant to the A.Y. 2013-14 was an unexplained investment made by the assessee under section 69 of the Act since the assessee had been found to be the owner of the investment, since

Renu Anandani, Jabalpur vs. NFAC, Delhi

In the result, the appeal is allowed for statistical purposes

ITA 120/JAB/2023[2012-13]Status: DisposedITAT Jabalpur28 Nov 2025AY 2012-13

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Neeraj Agarwal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR

Section 143(3)Section 147Section 263

been made for such investment.AO had considered market rate on the date of transfer to Demat account from physical form and considered it as unexplained investment. Findings as ultimately recorded by AO had been based more on presumptions rather than on cogent proof and is bad in law and should ... investment of Rs. 28,89,600/-. Therefore, he added back the balance of Rs. 7,16,972/- in the hands of the assessee as unexplained investment under section 69B of the I.T. Act. Furthermore, the ld. AO noted that short term capital gain of Rs. 3,69,039/- only

Bhupatbhai Dhanjibhai Kothari, Surat vs. ITO, Ward 2(3)(1), Surat

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

ITA 578/SRT/2025[2011-12]Status: DisposedITAT Surat28 Nov 2025AY 2011-12

Bench: Shri Bijayananda Pruseth, Am Arate Sitet F/Ita No.578/Srt/2025 Assessment Year: (2011-12) (Physical Hearing)

Section 139(1)Section 147Section 249(3)Section 271(1)(c)Section 69

credit entries. The amount of Rs.10,44,000/- (cash deposit) and Rs.2,45,725/- (credit entries), totaling to Rs.12,89,725/- was treated as unexplained investment u/s 69 of the Act and added to his income. Later on, penalty proceedings u/s 271(1)(c) of the Act were also initiated

Andhara Pradesh Education and Welfare Infrastructure Development Corporation, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

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

ITA 558/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2020-21

Bench: the Ld. CIT(A). The Ld. CIT(A) dismissed the appeals of the assessee ex-parte for both the assessment years by observing as under:

Section 144BSection 147Section 250Section 69A

profit (@8% of business turnover/ 2,00,46,107 gross receipts i.e. Rs.25,05,76,339/-) Interest on fixed deposits 5,81,80,051 Unexplained investment in car 19,26,000 3. Aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A). The Ld. CIT(A) dismissed

Andhara Pradesh Education and Welfare Infrastructure Development Corporation, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

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

ITA 557/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2019-20

Bench: the Ld. CIT(A). The Ld. CIT(A) dismissed the appeals of the assessee ex-parte for both the assessment years by observing as under:

Section 144BSection 147Section 250Section 69A

Binukala Sivarajendran, Thiruvananthapuram vs. The Income Tax Officer, Thiruvananthapuram

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

ITA 865/COCH/2025[2019-20]Status: DisposedITAT Cochin28 Nov 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2019-20 Binukala Sivarajendran .......... Appellant Arun Gardens, Vellamkettuvila, Nemom P.O. Thiruvananthapuram [Pan: Djdps8683E] Vs. Ito, Ward-2(1), Thiruvananthapuram .......... Respondent Assessee By: Shri Mathew Joseph, Ca Revenue By: Ms. Neethu S. Sr. Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 28.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 21.03.2025 For Assessment Year (Ay) 2019-20. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income For Ay 2019-20 Was Filed By The Appellant. Based On The Information That The Appellant Purchased Bonds/Debentures Valued At Rs. 20,00,000/- During Previous Year Relevant To The Assessment Year Under Consideration, The Ao Formed An Opinion That Income Escaped Assessment To Tax. Therefore, A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) Was Issued

For Appellant: Shri Mathew Joseph, CAFor Respondent: Ms. Neethu S. Sr. DR

Section 147Section 148Section 148A

total income of Rs. 20,12,800/-. While doing so, the AO made addition of Rs. 20,00,000/- as unexplained investment of the appellant. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order dismissed the appeal without condoning the delay

Jagir Kaur, Chandigarh vs. Income Tax Officer, Ward - 5(5), Chandigarh

In the result, appeal of the Assessee is allowed

ITA 951/CHANDI/2025[2013-14 ]Status: DisposedITAT Chandigarh28 Nov 2025

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 147Section 148

explain the source of the cash deposit of Rs. 12,00,000/- with credible evidence, the Assessing Officer treated the said amount as unexplained investment under section 69 of the Income-tax Act, 1961, and added it to the assessee’s total income. Consequently, the total assessed income was computed ... cultivation remain unchallenged. 8.3 With regard to the applicability of Section 69 of the Act, the deeming provision can be invoked only when an unexplained investment is found to belong to the assessee and the source thereof is not satisfactorily explained. In the present case, the assessee has explained

ACIT CC 2(3) Ahmedabad, Ahmedabad vs. Aisha Dhiraj Gogia, Ahmedabad

In the result: 50. To summarize the final outcome:

ITA 1673/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha["ी संजय गग", "ाियक सद" एवं "ी नरे" साद िस!ा, लेखा सद" के सम#।]

extrapolated this rate to the assessee's land, recomputed the purchase value at Rs. 25,86,37,500/-, and treated the difference as unexplained investment and made the addition of Rs. 24,21,37,500/- alleging that assessee had paid on-money to that extent for acquiring the said property ... that the pressure of search was built so much that he had to make the surrender without having actual possession of the assets or unexplained investments or expenses incurred and that there was no such income as undisclosed. The Hon’ble Delhi High Court, after considering the fact and circumstances

Apaasso Mali, Pune vs. ITO 11(1), Swargate

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

ITA 1110/PUN/2025[2018-19]Status: DisposedITAT Pune28 Nov 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Suhas KulkarniFor Respondent: Shri A D Kulkarni

Section 142(1)Section 144Section 147Section 147rSection 148Section 249Section 249(2)

case and in law, the Learned Assessing Officer has erred in treating the amount of ₹21,75,000/- related to time deposits as unexplained investment under Section 69 of the Income Tax Act ignoring the fact that these deposits were made through the sweep account facility linked to the current