unexplained investment — 5,821 case laws

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

In the result the appeal of the assessee in ITA no

ITA 513/JPR/2025[2016-17]Status: DisposedITAT Jaipur14 Oct 2025AY 2016-17

For Appellant: Shri S. L. Poddar, AdvFor Respondent: Mrs. Anita Rinesh, JCIT, Sr-DR

Section 132Section 139Section 153ASection 234B

Madhya Pradesh)/[2019] 265 Taxman 81 (Madhya Pradesh) (MAG)[22-03-2018] as under:- Headnotes Section 69 of the Income-tax Act, 1961- Unexplained investment (Immovable property) - Assessment year 2006-07-Whether wherefrom statement of one SKL it was evident that assessee engaged in construction business had entered into ... original owner of land and paid Rs.20 lakhs towards advance (bayana) for purchase of said land, Tribunal rightly upheld addition of Rs.20 lakhs as unexplained investment under section 69 Held, yes Whether, findings recorded by authorities being findings of fact based on agreement of purchase of land, it could

Tanveer Bano, Unnao vs. Income Tax Officer Ward-2(4), Unnao

In the result, the appeal is allowed for statistical purposes

ITA 430/LKW/2025[2019-20]Status: HeardITAT Lucknow14 Oct 2025AY 2019-20

Bench: Shri Anadee Nath Misshra

Section 115BSection 144Section 147Section 253(3)Section 56(2)(x)Section 69Section 69A

Rs.1,55,000/- from her savings. The AO as well as the CIT(A)/NFAC was not justified and treating the same as unexplained investment u/s.69 making the addition of Rs.6,90,000/-and also apply the provisions of section 115BBE, the addition made, be deleted. I.T.A. No.430/Lkw/2025 Assessment Year

Balwinder Kaur, Fatehabad, Haryana vs. ITO, Ward-1, Fatehabad, Haryana

In the result, the appeal of the Assessee stands allowed

ITA 446/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh14 Oct 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 446/Chd/2025 "नधा"रण वष" / Assessment Year : 2017-18 Balwinder Kaur, The Ito, बनाम W/O Sh. Sukhwant Singh Ward 1, Village Aherwan, Fatehabad Vs. P.O. Aherwan Ratia, Fatehabad, Haryana 125051 "थायी लेखा सं./Pan No. Gyzpk9424B अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, C.A. राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 31-07-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 14-10-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 07.02.2025 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: Sh. Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 115BSection 142(1)Section 148Section 250Section 69Section 69A

Worthy CIT(A) has erred in confirming the addition made by the Ld. AO of Rs. 8,95,499/-u/s 69 on account of unexplained investment in acquisition of immovable asset even when the same was explained. 6. That on facts, circumstances and legal position of the case, Worthy

Ramalingam Ellalan, Erode vs. ACIT, Central Circle-2, Coimbatore

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

ITA 1129/CHNY/2025[2018-19]Status: DisposedITAT Chennai14 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:1129/Chny/2025 धििाारणवर्ा / Assessment Year:2018-19 Ramalingam Ellalan, The Assistant Commissioner 279/1, Sathy Road, Vs. Of Income Tax, Erode – 638 003. Central Circle-2 Tamil Nadu. Coimbatore. [Pan:Aafpe-9379-M] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit.

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anitha, CIT

Section 115BSection 133ASection 139(4)Section 143(1)Section 147Section 148

pertains to assessment year 17- 18. With regard to remaining sum of Rs 18,70,000/-, the Learned CITA observed that the same represent unexplained investment made during the year under consideration to be taxed at the enhanced rate of tax prescribed under section 115BBE of the Act. Aggrieved, only ... includes Rs 12,28,000/- which was paid subsequently to the data of availing the housing loan. Hence, the actual amount of unexplained investment made in the year under consideration is only Rs. 18,70,000 (Rs. 30,98,000 minus Rs. 12,28,000. However, the appellant had offered

Ruby Rajendra P Tiwari, Mumbai vs. ITO Ward 42(3)(2), Mumbai

Appeal is treated as allowed for statistical purposes

ITA 3546/MUM/2025[2016-17]Status: DisposedITAT Mumbai14 Oct 2025AY 2016-17

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Sanjay ChaudharyFor Respondent: Shri Annavaran Kosuri

Section 144Section 144BSection 147Section 192Section 45Section 69ASection 69C

Rs.1,17,44,910. It appears that the addition has been made twice of the same amount (55,00,000+55,00,000 (Unexplained Investment) + 3,72,455 + 3,72,455 (Credit Card Bills)). 6. The Ld. A.O. has erred in law and facts by reopening of Assessment under

Nishant Parekh - Legal Heir of Mina Parekh, Jamnagar vs. Income Tax Officer, Ward 1(3), Jamnagar

The appeal of the assessee is allowed

ITA 196/RJT/2025[2012-13]Status: DisposedITAT Rajkot13 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 196/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2012-13) Nishant Parekh – Legak Heir Of Mina Income Tax Officer, Wd – 1(3), Parekh Vs. Aayakar Bhavan, 322, Madhav Square, Opp. Avantika Jamnagar – 361001 Complex, Limda Lane Road, Jamnagar – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 10(38)Section 147Section 250

facts as it has erred in making additions under Sections 69 of the Income Tax Act, 1961, amounting to 27,50,000/- and alleging unexplained investments and unexplained money, respectively without considering the fact that the assessee duly furnished documentary evidence from the third party including bank statements and confirmation ... amounting to 27,50,000/-. The brief facts qua the issue are that an addition of Rs. 27,50,000/- as unexplained investment in shop, was proposed by the assessing officer, therefore, assessing officer issued a notice to the assessee to explain the investment in Shop. In response, the assessee

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 748/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Oct 2025AY 2019-20

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

investment is not at all related to the year under consideration, there is no question to make addition therein u/s.69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 733/JPR/2025[2018-19]Status: DisposedITAT Jaipur13 Oct 2025AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

Section 153ASection 250

investment is not at all related to the year under consideration, there is no question to make addition therein u/s.69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 602/JPR/2025[2021-22]Status: DisposedITAT Jaipur13 Oct 2025AY 2021-22

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

related to the year under consideration, there is no question to make addition therein u/s. 69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment during the current year ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

ITA 551/JPR/2025[2019-20]Status: DisposedITAT Jaipur13 Oct 2025AY 2019-20

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

investment is not at all related to the year under consideration, there is no question to make addition therein u/s.69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 534/JPR/2025[2018-19]Status: DisposedITAT Jaipur13 Oct 2025AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

related to the year under consideration, there is no question to make addition therein u/s. 69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment during the current year ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 460/JPR/2025[2017-18]Status: DisposedITAT Jaipur13 Oct 2025AY 2017-18

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

related to the year under consideration, there is no question to make addition therein u/s. 69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment during the current year ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 442/JPR/2025[2016-17]Status: DisposedITAT Jaipur13 Oct 2025AY 2016-17

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

investment is not at all related to the year under consideration, there is no question to make addition therein u/s.69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

In the result, the appeals of the assessee are partly allowed

ITA 441/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Oct 2025AY 2015-16

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyal

For Appellant: Mr. Vinod Gupta, CA. Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 153ASection 250

investment is not at all related to the year under consideration, there is no question to make addition therein u/s.69 of the Act as unexplained investment since the very foundation of invoking section 69 of the Act in the current case is absent. Hence, in the absence of any investment ... carried out a search & seizure operation upon the assessee, therefore, it could easily discover the connection of this loose paper with any transaction, either unexplained investment in the machinery or anything else, but it could not collect any corroborative material from the assessee. The DDIT (Investigation) has called

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 246/JPR/2025[2016-17]Status: DisposedITAT Jaipur13 Oct 2025AY 2016-17

For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT

Section 144Section 147Section 250

explanation for the same. In the absence of any explanation from the appellant, the AO treated the whole amount Rs.1,97,67,171/- as unexplained investment under section 69 of the IT Act and completed the assessment under section 147 r.w.s.144 vide his order dated 28.03.2022 for the year under ... heard and to decide all the issues judiciously. Hence our submission hereinafter kindly be considered in this light. GOA-4 Addition on account of unexplained investment u/s 69: Facts: The AO noted in the case that, based on available information, theassessee Society deposited Rs.3,28,98,301/- in its bank

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 245/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Oct 2025AY 2015-16

For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT

Section 144Section 147Section 250

explanation for the same. In the absence of any explanation from the appellant, the AO treated the whole amount Rs.1,97,67,171/- as unexplained investment under section 69 of the IT Act and completed the assessment under section 147 r.w.s.144 vide his order dated 28.03.2022 for the year under ... heard and to decide all the issues judiciously. Hence our submission hereinafter kindly be considered in this light. GOA-4 Addition on account of unexplained investment u/s 69: Facts: The AO noted in the case that, based on available information, theassessee Society deposited Rs.3,28,98,301/- in its bank

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO, Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 244/JPR/2025[2014-15]Status: DisposedITAT Jaipur13 Oct 2025AY 2014-15

For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT

Section 144Section 147Section 250

explanation for the same. In the absence of any explanation from the appellant, the AO treated the whole amount Rs.1,97,67,171/- as unexplained investment under section 69 of the IT Act and completed the assessment under section 147 r.w.s.144 vide his order dated 28.03.2022 for the year under ... heard and to decide all the issues judiciously. Hence our submission hereinafter kindly be considered in this light. GOA-4 Addition on account of unexplained investment u/s 69: Facts: The AO noted in the case that, based on available information, theassessee Society deposited Rs.3,28,98,301/- in its bank

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

In the result, the appeals of the assessee are allowed

ITA 243/JPR/2025[2013-14]Status: DisposedITAT Jaipur13 Oct 2025AY 2013-14

For Appellant: Shri Deepak Sharma, C.AFor Respondent: Smt. Anita Rinesh, JCIT

Section 144Section 147Section 250

explanation for the same. In the absence of any explanation from the appellant, the AO treated the whole amount Rs.1,97,67,171/- as unexplained investment under section 69 of the IT Act and completed the assessment under section 147 r.w.s.144 vide his order dated 28.03.2022 for the year under ... heard and to decide all the issues judiciously. Hence our submission hereinafter kindly be considered in this light. GOA-4 Addition on account of unexplained investment u/s 69: Facts: The AO noted in the case that, based on available information, theassessee Society deposited Rs.3,28,98,301/- in its bank

Basera Realtors Private Limited, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana

In the result, the appeal of the Assessee is dismissed

ITA 34/CHANDI/2022[2007-2008]Status: DisposedITAT Chandigarh13 Oct 2025AY 2007-2008

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 34/Chd/2022 "नधा"रण वष" / Assessment Year : 2007-08 M/S Basera Realtors Pvt. Ltd., The Dcit, बनाम 10, Canal View, Near South Central Circle -1, City, Aggar Nagar, Ludhiana Vs. Ludhiana "थायी लेखा सं./ Pan No: Aaccb7360D अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : None ( Adjournment Application ) राज"व क" ओर से/ Revenue By : Smt. Tarundeep Kaur, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 09.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 13.10.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 22.05.2017 Passed By The Ld. Commissioner Of Income Tax (Appeals)-5, For A.Y. 2007- 08. 2. Grounds Of Appeal Are As Under:

For Appellant: None ( Adjournment Application )For Respondent: Smt. Tarundeep Kaur, CIT DR

Section 69

assessing 34-Chd-2022 Basera Realtors Pvt.Ltd., Ludhiana 2 officer out of total addition of Rs.4,18,87,582/- on account of unexplained investment u/s 69. 2. That without prejudice to Ground of Appeal No. 1, Ld CIT(A) erred in ignoring the fact that assessee owned only 50% share

Bhikhabhai H Patel, Gandhinagar vs. The ITO, Ward-1, Patan

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

ITA 886/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad13 Oct 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Parin Shah, ARFor Respondent: Shri Uday Kishanrao Kakne, Sr. DR

Section 143(2)Section 148Section 234ASection 250Section 271(1)(c)

passed is required to be quashed. 5. Ld. NFAC erred in law and on facts in confirming addition of Rs. 3,41,570/- as unexplained investment ignoring fact that payment is through banking channel only. 6. Ld. NFAC erred in law and on facts in confirming addition ... unexplained money. 8. Ld. NFAC erred in law and on facts in confirming addition of Rs. 17,00,000/- as unexplained investment. 9. Ld. NFAC erred in law and on facts in confirming addition of Rs. 1,67,400/- being stamp duty paid on purchase of property. 10. Ld. NFAC

“unexplained investment”

Leading authorities on unexplained investment

Judgments citing unexplained investment

Sunil Kumar Agarwal, Jaipur vs. ACIT, Cen. Cir-2, Jaipur

Tanveer Bano, Unnao vs. Income Tax Officer Ward-2(4), Unnao

Balwinder Kaur, Fatehabad, Haryana vs. ITO, Ward-1, Fatehabad, Haryana

Ramalingam Ellalan, Erode vs. ACIT, Central Circle-2, Coimbatore

Ruby Rajendra P Tiwari, Mumbai vs. ITO Ward 42(3)(2), Mumbai

Nishant Parekh - Legal Heir of Mina Parekh, Jamnagar vs. Income Tax Officer, Ward 1(3), Jamnagar

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Silver & Art Palace, Jaipur vs. ACIT, Jaipur

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO, Ward-1(2), Jaipur

Rms Karamchari Bachat and Sakh Sahakari Samiti Limited Jaipur, Jaipur vs. ITO Ward-1(2), Jaipur

Basera Realtors Private Limited, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana

Bhikhabhai H Patel, Gandhinagar vs. The ITO, Ward-1, Patan