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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

Monument Properties Private Limited, Bijapur vs. Income Tax Officer, Ward-1 & Tps, Bijapur

In the result, the appeal of the assessee is partly allowed for statistical purposes, as stated above

ITA 1404/BANG/2025[2018-19]Status: DisposedITAT Bangalore28 Nov 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharyassessment Year: 2018-19

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)
Section 115Section 115BSection 148Section 69

supporting material was filed to show the source of the same. Therefore, he added this amount under section 69 of the Act as unexplained investment and taxed it under section 115BBE of the Act. 4. The learned CIT(A) agreed with the AO. He held that the reopening was valid ... fixed deposits and failed to prove the genuineness of the transactions. Thus, the CIT(A) confirmed the addition of ₹5,43,57,921 as unexplained investment. 5. Being aggrieved by the order of learned CIT-A, the assessee is in appeal before us. 6. The learned AR filed a paper

Manish Vijay Chembur Co Operative Housing Society, Mumbai vs. National Faceless Appeal Center, New Delhi

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

ITA 4953/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Nov 2025AY 2015-16

Bench: Us Assessee Has Filed Following Submissions:-

Section 144Section 69

their flats. The AO made addition of Long Term Capital Gains of Rs 35.51 crore for sale of property and Rs 6.33 crore as unexplained investment u/s 69 of the act for purchase of property on basis of Insight portal eventhough there was no redevelopment, no sale nor any purchase ... Addition of Long Term Capital gains of Rs 35.51 crores for sale of Immovable Property and Rs 6.33 crore as unexplained investment for purchase of Immovable Property 4 Manish Vijay Chembur Co- operative Housing Society a) There is neither sale nor purchase of any immovable property b) The appellant society

Veda Real Estate Corporation Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

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

ITA 3221/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 Nov 2025AY 2013-14

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

Section 132Section 132(4)Section 148Section 234BSection 250Section 69A

excel sheets found during the course of search, the evidentiary worth of the statements recorded under section 132(4), and the consequential additions of unexplained investments under section 69A/69B of the Act. 3. Brief facts as culled out from the records are that the assessee is a part ... lands at Agarsure. On this premise, the Assessing Officer held that the said payment represented unaccounted investment in land and, therefore, treated them as unexplained investment under section 69A/69B of the Act. 8 Veda Real Estate Corporation Private Limited0 14. Based on this reasoning, the Assessing Officer made addition under

Veda Real Estate Corporation Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

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

ITA 3219/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

Section 132Section 132(4)Section 148Section 234BSection 250Section 69A

excel sheets found during the course of search, the evidentiary worth of the statements recorded under section 132(4), and the consequential additions of unexplained investments under section 69A/69B of the Act. 3. Brief facts as culled out from the records are that the assessee is a part ... lands at Agarsure. On this premise, the Assessing Officer held that the said payment represented unaccounted investment in land and, therefore, treated them as unexplained investment under section 69A/69B of the Act. 8 Veda Real Estate Corporation Private Limited0 14. Based on this reasoning, the Assessing Officer made addition under

Veda Real Estate Corporation Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

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

ITA 3218/MUM/2025[2014-15]Status: DisposedITAT Mumbai28 Nov 2025AY 2014-15

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

Section 132Section 132(4)Section 148Section 234BSection 250Section 69A

excel sheets found during the course of search, the evidentiary worth of the statements recorded under section 132(4), and the consequential additions of unexplained investments under section 69A/69B of the Act. 3. Brief facts as culled out from the records are that the assessee is a part ... lands at Agarsure. On this premise, the Assessing Officer held that the said payment represented unaccounted investment in land and, therefore, treated them as unexplained investment under section 69A/69B of the Act. 8 Veda Real Estate Corporation Private Limited0 14. Based on this reasoning, the Assessing Officer made addition under

Veda Real Estate Corporation Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

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

ITA 3217/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Nov 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Om Prakash Kant

Section 132Section 132(4)Section 148Section 234BSection 250Section 69A

excel sheets found during the course of search, the evidentiary worth of the statements recorded under section 132(4), and the consequential additions of unexplained investments under section 69A/69B of the Act. 3. Brief facts as culled out from the records are that the assessee is a part ... lands at Agarsure. On this premise, the Assessing Officer held that the said payment represented unaccounted investment in land and, therefore, treated them as unexplained investment under section 69A/69B of the Act. 8 Veda Real Estate Corporation Private Limited0 14. Based on this reasoning, the Assessing Officer made addition under

Assistant Commissioner of Income Tax, Delhi vs. Manoj Kumar Bansal, Delhi

In the result the appeal of the Revenue is dismissed

ITA 1041/DEL/2025[2019-20]Status: DisposedITAT Delhi28 Nov 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2019-20 Assistant Commissioner Of Vs. Manoj Kumar Bansal, 401 Income Tax Room No. New Delhi House, 27 Barakhamba 261-A 2Nd Floor F-2 Ara Road Delhi 110001 Centre, New Delhi- 110055 Pan No.Aahpb3143F (Appellant) (Respondent)

Section 132Section 139(1)Section 143(2)Section 143(3)Section 147Section 148Section 69Section 69ASection 69C

based upon the search conducted in the premise of a third party, issued reassessment and proceeded to add Rs. 9,30,00,000/- as unexplained investment under Section 68 of the Income-tax Act, 1961 (hereafter referred to as "the Act). 7. Admittedly, the assessee has taken the loan from

Malkiat Singh Dhaliwal, Ferozepur City vs. ITO, Ferozepur Cantt

In the result, the appeal of the assessee is allowed

ITA 239/ASR/2025[2012-13]Status: DisposedITAT Amritsar27 Nov 2025AY 2012-13

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 239/Asr/2025 Assessment Year: 2012-13 Malkiat Singh Dhaliwal S/O Vs. Ito, Joginder Singh 37, Dashmesh Ferozepur. Nagar, Near Baghi Hospital Ferozepur City Punjab. [Pan:-Aalpd0965E] (Respondent) (Appellant) Appellant By None (Adjournment Application) Sh. Charan Dass, Sr. Dr Respondent By Date Of Hearing 12.11.2025 Date Of Pronouncement 27.11.2025

Section 143(3)Section 148

accepted the agricultural income of Rs. 1.50 lakhs for the year but added back the balance amount of Rs. 4.02 lakhs as unexplained investment for purchase of land. 5. The matter carried in first appeal has been partly allowed by the Ld. first appellate authority who deleted an amount

Adarsh Nursing Institute Pvt Ltd., Raipur vs. ITO-4(1), Raipur

In the result, appeal of the assessee is allowed

ITA 534/RPR/2025[2014-15]Status: DisposedITAT Raipur27 Nov 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.534/Rpr/2025 "नधा"रण वष" /Assessment Year : 2014-15 Adarsh Nursing Institute Private Limited Behind Sejbahar, Housing Board Colony, Near Kushabhau Thakre Univeristy, Datrenga, Raipur (C.G.)-492 013 Pan: Aagca6544C

For Appellant: None (Adjournment Petition)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 68

assessee by way of self speaking documentary evidence and explanation. Secondly, the AO has made addition u/s 69 of the Act which pertains to unexplained investments, whereas the assessee has not made any investment either in movable or any immovable property during the relevant period by way of using cash ... follows: “5. At the outset, on this issue, it is noted that the AO had made addition u/s.69 of the Act which refers to unexplained investment. However, in this case, the assessee had neither purchased nor sold any moveable or immoveable property, nor had invested in any such property

Kusum Mittal, Sangrur vs. Income Tax Officer, Ward - Sangrur, Sangrur

In the result, the appeal of the assessee is allowed

ITA 941/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh27 Nov 2025AY 2015-16

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

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 147Section 148Section 151Section 69

investment as loans received from various parties. The Assessing Officer accepted some sources and rejected others aggregating to Rs.71,50,000/-, treating them as unexplained investment under section 69. The CIT(A), after detailed consideration, deleted Rs.25,00,000/- relating to loan from Shri Darshan Kumar and confirmed the balance

Hitesh Balchandra Rawal, Gandhinagar vs. Income-Tax Officer, Ward-2, Gandhinagar

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

ITA 1984/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice- & Shri Siddhartha Nautiyalhitesh Balchandra Rawal, The Income Tax Officer, Vs. Poojan Plot No.781/2, Ward-2, Sector-2C, Gandhinagar. Gandhinagar-382002. [Pan :Afepr8090 N] (Appellant) .. (Respondent) Appellant By : Shri Vijay H Patel, Ar Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 25.11.2025 Date Of Pronouncement 27.11.2025

For Appellant: Shri Vijay H Patel, ARFor Respondent: Shri Abhijit, Sr. DR
Section 69

Hotels Ltd. Since the assessee failed to provide any documentary evidence explaining the source of such investment, the Assessing Officer treated the same as unexplained investment and made an addition under section 69 of the Act. 4. Aggrieved by the assessment order, the assessee preferred an appeal before

Ambience Management and Compliance Services Pvt. Ltd., Erode vs. ITO, Ward-1(1), Erode

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

ITA 2475/CHNY/2025[2013-14]Status: DisposedITAT Chennai27 Nov 2025AY 2013-14

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.2475/Chny/2025 िनधा8रण वष8 /Assessment Year: 2013-14

For Appellant: Shri S. Bhupendran, AdvocateFor Respondent: Ms. M. Subashri, Addl. CIT(virtual)
Section 147

thereafter completed the assessment ex-parte u/s 147 r.w.s. 144 of the Act, making an addition of Rs. 2,80,00,000/- as unexplained investment. On appeal, the Ld. CIT(A) set aside the matter for a fresh assessment on the ground that the assessee was not provided proper opportunity

Manoj Arjun Nasta, Mumbai - Currently Resident in Uae vs. Income Tax Offcer Ward 42(2)(4), Ward 42(2)(4)

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

ITA 5809/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(b)Section 271(1)(c)

this consolidated order. 2. The primary dispute relates to the addition of ₹ 62,00,000/- made by the Assessing Officer towards the alleged unexplained investment in the purchase of immovable property. The learned counsel submitted that the assessee has been a Non-Resident Indian for several decades, permanently employed abroad

Manoj Arjun Nasta, Mumbai - Currently Resident in Uae vs. Income Tax Officer, Ward 42(2)(4)

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

ITA 5808/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(b)Section 271(1)(c)

this consolidated order. 2. The primary dispute relates to the addition of ₹ 62,00,000/- made by the Assessing Officer towards the alleged unexplained investment in the purchase of immovable property. The learned counsel submitted that the assessee has been a Non-Resident Indian for several decades, permanently employed abroad

Manoj Arjun Nasta, Mumbai - Currently Resident in Uae vs. The Assistant Commissioner of Income Tax, Circle 42(2)(1), Mumbai

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

ITA 5807/MUM/2025[2016-17]Status: DisposedITAT Mumbai27 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 147Section 271(1)(b)Section 271(1)(c)

this consolidated order. 2. The primary dispute relates to the addition of ₹ 62,00,000/- made by the Assessing Officer towards the alleged unexplained investment in the purchase of immovable property. The learned counsel submitted that the assessee has been a Non-Resident Indian for several decades, permanently employed abroad

Ravindra Kumar Vishwanath Yadav, Mumbai vs. ITO Ward 28(2)(1), Mumbai

In the result, the assessee’s appeal is allowed

ITA 4960/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Nov 2025AY 2015-16

Bench: Shri Narender Kumar Choudhryassessment Year: 2015-16 Mr. Ravindrakumar Vishwanath The Ito, Ward 28 (2)(1), Yadav, Tower 6, Vashi Railway Room No.1118, Samta Nagar Vs. Station Commercial Sector 1A, Airoli, Navi, Complex, Vashi, Mumbai – 400708 Navi Mumbai – 400703. Pan – Acbpy0748G. (Appellant) (Respondent) Present For: Assessee By : Shri Dharan Gandhi. Revenue By : Shri Sunil Mathews, Ld. Sr. D.R. Date Of Hearing : 13.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.03.2024, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2015-16. 2. In This Case, The Assessing Officer (A.O.) Vide Assessment Order 11.03.2024 U/S. 147 R.W.S. 144 R.W.S. 144 B Of The Act, Has Made The Addition Of Rs. 14,75,000/- Being Variation In Respect Of Unexplained Investment U/S. 69 Of The Act.

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sunil Mathews, Ld. Sr. D.R
Section 147Section 148Section 149Section 149(1)(b)Section 250Section 3Section 69

r.w.s. 144 r.w.s. 144 B of the Act, has made the addition of Rs. 14,75,000/- being variation in respect of unexplained investment u/s. 69 of the Act. 3. The Assessee, thus being aggrieved, challenged the said addition by filing first appeal before the Ld. Commissioner, however

Dy. Commissioner of Income Tax, Noida vs. M/S Ace Mega Structure Private Limited, Noida

In the result, appeal of the assessee is allowed

ITA 4115/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

Income-tax Act, 1961 are not applicable to the facts of the case. The basis of the addition pertains to alleged unexplained investment, whereas Section 69C specifically applies to unexplained expenditure. Therefore, the invocation of Section 69C is erroneous and unsustainable in law.” 10. Ground of appeal No.3 raised

Ace Mega Structures Private Limited, Uttar Pradesh vs. DCIT/ACIT Cen Cir, Noida

In the result, appeal of the assessee is allowed

ITA 4067/DEL/2025[2019-20]Status: DisposedITAT Delhi27 Nov 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Manish Agarwalsl. Ita No(S) Asst. Appeal(S) By No Year(S) Appellant Vs. Respondent Appellant Respondent 1. 4067/Del/2025 2019-20 M/S. Ace Mega Dcit/Acit Structures Pvt. Ltd., Central Circle I-B, 7Th Floor, Ace Studio, Noida Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D M/S. Ace Mega 2. 4115/Del/2025 2019-20 Dcit, Structures Pvt. Ltd. Central Circle-1, A.R.T.O Complex, Sector-33, I-B, 7Th Floor, Ace Studio, Noida-201301. Sector-126, Noida, Sector- 37, S.O. Gautam Budh Nagar-201303 Pan-Aakca8694D Appellant By Shri Rohit Kapoor, Adv. & Shri Virsain Aggarwal, Itp Respondent By Shri Mahesh Kumar, Cit Dr Date Of Hearing 17.09.2025 Date Of Pronouncement 27.11.2025

Section 147Section 68

Income-tax Act, 1961 are not applicable to the facts of the case. The basis of the addition pertains to alleged unexplained investment, whereas Section 69C specifically applies to unexplained expenditure. Therefore, the invocation of Section 69C is erroneous and unsustainable in law.” 10. Ground of appeal No.3 raised

Shobha Devi, Jhansi vs. Income Tax Officer, Jhansi, Up

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

ITA 429/AGR/2025[2018-19]Status: DisposedITAT Agra26 Nov 2025AY 2018-19

Bench: Shri M. Balaganesh(Through Virtual Hearing) Shobha Devi, Vs. Income Tax Officer, 285, Suri Wali Gali, Ward-2(3)(1), Near Masjid Pratap Jhansi Pura Nagar, Sipri Bzaaar, Jhansi, Up (Appellant) (Respondent) Pan: Ainpd4091R Assessee By : None Revenue By: Shri Anil Kumar, Sr Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 26/11/2025

For Appellant: NoneFor Respondent: Shri Anil Kumar, Sr DR
Section 144BSection 147Section 148Section 69

appeal is as to whether the Learned CIT(A) was justified in confirming the addition of Rs 12,19,200/- made on account of unexplained investment under section 69 of the Act in the facts and circumstances of the instant case. The next issue to be decided in this appeal ... against the returned income of Rs. 6,42,980/- after making the addition of Rs. 12,19,200/- on account of unexplained investment under Section 69 r.w.s 115BBE of the Act and another addition of Rs. 34,583/- on account of interest income. On perusal of the order

Meera Yadav, Jhansi vs. Deputy Commissioner of Income-Tax, Circle 2(1)(1), Agra

In the result, ITA No. 359, 394 and 360/Agr/2025 are allowed for

ITA 394/AGR/2025[2017-2018]Status: DisposedITAT Agra26 Nov 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 142(1)Section 143(1)Section 144Section 147Section 148Section 250Section 37

which was processed u/s. 143(1) of the Act. Subsequently, based on the information available with the department that the assessee had made unexplained investment in immovable property amounting to Rs.53,84,984/- during the financial year 2016-17 (as per election affidavit filed during MP General Election 2018, Niwari ... Considering assessee’s response, Ld. Assessing Officer completed the assessment and made various additions on account of undisclosed business receipts, unexplained investment and undisclosed interest income and assessed total income of assessee at Rs.4,23,44,210, vide assessment order dated 19.03.2025 passed u/s. 147/144/144B