“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

Muthiah Lakshmanan, Chennai vs. ITO Ncw 10(3), Chennai

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

ITA 1958/CHNY/2025[2011-12]Status: DisposedITAT Chennai23 Sept 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. No.1958/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Muthiah Lakshmanan, Vs. The Income Tax Officer, 16/3, Seethaamma Colony, 1 Main Non Corporate Ward 10(3), Road, 2Nd Street, Alwarpet, Teynampet, Chennai. Chennai 600 018. [Pan:Adopl7512R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. T.V. Muthu Abirami, Advocate ""थ" की ओर से/Respondent By : Ms. Sandhya Rani Kure, Jcit सुनवाई की तारीख/ Date Of Hearing : 18.09.2025 घोषणा की तारीख /Date Of Pronouncement : 23.09.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.11.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2011-12. 2. On Perusal Of The Assessment Order, We Note That The Assessing Officer Made Additions On Account Of Income From Speculation & Income From Unexplained Investment. Admittedly, No Return Of Income

For Appellant: Ms. T.V. Muthu Abirami, AdvocateFor Respondent: Ms. Sandhya Rani Kure, JCIT

Section 144Section 148Section 69A

perusal of the assessment order, we note that the Assessing Officer made additions on account of income from speculation and income from unexplained investment. Admittedly, no return of income 2 I.T.A. No.1958/Chny/25 was filed by the assessee even in response to the notice under section 148 of the Income ... placed on record. Further, cash deposits to an extent of ₹.38,88,500/- added to the total income of the assessee on account of unexplained investment under section 69A of the Act for being no compliance from the assessee and completed the assessment under section 144 of the Act dated

Vedic Foundation Private Limited, Delhi vs. Income Tax Officer, Ward 26(2), Delhi

Appeal is allowed

ITA 4975/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Sept 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 4975/Del/2025 : Asstt. Year : 2017-18 Vedic Foundation Pvt. Ltd., Vs Income Tax Officer, 43-B, First Floor, Mig Flat, Ward-26(2), Pocket-B Dilshad Garden, New Delhi-110002 New Delhi-110095 (Appellant) (Respondent) Pan No. Aaaci8590C Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 23.09.2025 Date Of Pronouncement: 23.09.2025 Order This Assessee’S Appeal For Assessment Year 2017-18, Arises Against The Addl./Jcit(A), Panchkula’S Din & Order No. Itba/Apl/S/250/2025-26/1077029340(1) Dated 13.06.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 143(2)Section 143(3)Section 69

proceeded ex-parte. 3. Coming to the assessee’s sole substantive grievance challenging correctness of both the lower authority’s action making section 69 unexplained investment addition amounting to Rs.14,32,346/- in shares, in the course of assessment framed on 30.12.2019 and upheld in the lower appellate proceedings ... instant sole substantive grievance as well as the Revenue’s vehement contentions. I am of the considered view that once the impugned issue of unexplained investment nowhere formed subject matter of “limited” scrutiny exercise herein, both the learned lower authorities could not have added it in light of PCIT

Arjan Lila Goraniya, Porbandar vs. ITO Ward 2(4), Porbandar

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

ITA 378/RJT/2025[2013-14]Status: DisposedITAT Rajkot22 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainiआयकरअपीलसं आयकरअपीलसं./Ita No.378/Rjt/2025 "नधा"रणवष" "नधा"रणवष" / Assessment Year: (2013-14) Arjan Lila Goraniya Vs. Ito Ward 2 (4), Inajiya Vadi Vistar, Porbandar - 360575 Porbandar Bhojeshwar S.O, Porbandar Bhojeshwar S.O, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./ ./Pan/Gir No.: Bbwpg1554P (Appellant) (Respondent)

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld

Section 144Section 148Section 234ASection 249(4)Section 250Section 271(1)(c)Section 69

invested, Rs. 65,20,805/ Rs. 65,20,805/-, in purchase of this property was was treated by the assessing officer, as unexplained as unexplained investment u/s 69 of the I.T T. Act and treated as income of the assessee for the Act and treated as income of the assessee ... appellant, AO made addition of Rs. 65,20,805/-, compliance of the appellant, AO made addition of Rs. 65,20,805/ on account of unexplained investment for the purchase of agricultural land u/s 69 of on account of unexplained investment for the purchase of agricultural land

Shri Vishwakarama Jewellers, Akola vs. DCIT Akola Circle, Akola

In the result, assessee’s appeal is allowed

ITA 99/NAG/2025[2017-18]Status: DisposedITAT Nagpur22 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri S.G. GandhiFor Respondent: Shri Surjit Kumar Saha

Section 115BSection 133ASection 143(3)Section 69B

property, (iii) 'profits and gains from business or profession', (iv) 'capital gains' and (v) 'income from other sources cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon'ble Gujarat High Court is that source of acquisition of asset or expenditure should be clearly

Late Sh. Lakha Singh Through Legal Heir Hira Singh Dera Pyara Singh Barna Thanesar Kurukshetra, Kurukshetra vs. The Income Tax Officer Ward-1 Aaykar Bhawan, Near Community Hall Sector-5, Kurukshetra Haryana, Kurukshetra

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

ITA 1151/CHANDI/2024[2012-2013]Status: DisposedITAT Chandigarh22 Sept 2025AY 2012-2013

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 144Section 148

completed reassessment u/s 144 r.w.s. 147 on 09.12.2019, determining total income of Rs.39,40,000/-. The additions comprised (i) Rs.60,00,000/- towards alleged unexplained investment in land, and (ii) Rs.39,40,000/- towards unexplained cash deposits in bank. 3.1 The assessee, Late Sh. Lakha Singh, unfortunately expired

Vilasben Purohit, Mumbai vs. Income Tax Officer 42(1)(5), Mumbai

ITA 4879/MUM/2025[2016-2017]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vilasben Purohit, Ito 42(1)(5), A 404, Snehal Tower, Sayar Pada, Kautilya Bhavan, Bandra Kurla Borivali, Vs. Complex, Mumbai-400066. Mumbai-400051. Pan No. Aqqpp 6847 J Appellant Respondent

For Appellant: Ms. Kavitha Kaushik, Sr. DRFor Respondent: Mr. Ashish Thakurdesai

Section 148Section 148ASection 234ASection 234BSection 69

115BBE of the Income Tax u/s 69 r w s 115BBE of the Income Tax Act, 1961 as unexplained investment. Act, 1961 as unexplained investment. 3. On facts, in circumstances of the case and in law, the On facts, in circumstances of the case and in law, the On facts

Subbarao Jaladi, Guntur vs. Income Tax Officer, Ward-2(1), Guntur

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

ITA 296/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Sept 2025AY 2018-19

Bench: Shri S Balakrishnan, Hon’Ble & Shri Sandeep Singh Karhail, Hon’Bleआयकर अपील सं./I.T.A. No. 296/Viz/2025 (निर्धारण वर्ा/ Assessment Year:2018-19) Subbarao Jaladi V. Income Tax Officer-Ward-2(1) Guntur, Andhra Pradesh 3-34 Pasumarru Village Chilakuluripet Mandal Guntur District Chilakaluripet – 522616 Andhra Pradesh [Pan:Actpj9648L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 133(6)Section 143(2)Section 143(3)Section 250Section 69

assessee is against the addition made under section 69 of the Act by treating the cash deposits made in his bank account as an unexplained investment. 4. Brief facts of the case pertaining to this issue are that the assessee is an individual who derives his income from business ... Ld.AO vide order dated 21.04.2021 passed under section 143(3) r.w.s. 144B of the Act treated the entire sum of cash credits as an unexplained investment under section 69 of the Act and added the same to the total income of the assessee. 5. The Ld. CIT(A), vide impugned

Kbn Infrastructure Private Limited, Mumbai vs. Income Tax Officer Ward 3(2)(3), Mumbai

In the result, the appeal is partly allowed

ITA 1455/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Prabhash Shankarkbn Infrastructure Private V/S. Income Tax Officer, Ward – Limited बनाम 3(2)(3), Room No. 673A, 6Th B-426, Nbc Complex, Plot No. Floor, Aayakar Bhavan, 43, Sector-11, Cbd Belapur, Mumbai – 400020, Navi Mumbai - 400 614, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadck3271B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Ashwani Kumar and Ms. Deepali Aggarwal,ARsFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 115BSection 143(3)Section 250Section 271ASection 271DSection 68Section 69Section 69A

there was no reason to interfere with the action of the AO in charging the relevant anti-abuse provisions of the act upon these unexplained investments, unexplained borrowing and unexplained cash credits. Additions were confirmed and accordingly, appeal was dismissed. P a g e | 7 A.Y. 2018-19 KBN Infrastructure

Sh. Mohinder Singh Arora, Delhi vs. ITO Ward-49(5), Delhi

Appeal of the assessee is allowed

ITA 2615/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.2615/िद"ी/2025 (िन.व. 2012-13) Mohinder Singh Arora, Wz-59, 2Nd Floor, Jail Road, Virender Nagar, New Delhi 110058 ...... अपीलाथ"/Appellant Pan: Aaspa-4694-G बनाम Vs. Income Tax Officer, Ward -49(5) ..... "ितवादी/Respondent Delhi अपीलाथ" "ारा/Appellant By : S/Shri Lalit Mohan & Ankit Kumar, Advocates "ितवादी"ारा/Respondent By : Ms. Sudha Gupta, Sr.Dr सुनवाई क" ितिथ/ Date Of Hearing : 29/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 29/07/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 27.03.2025, For Assessment Year 2012-13. 2. The Assessee In Appeal Has Inter Alia Assailed Validity Of Assessment U/S. 147 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) As Well As, Addition On Merits.

For Appellant: S/Shri Lalit Mohan & Ankit Kumar, AdvocatesFor Respondent: Ms. Sudha Gupta, SR.DR

Section 144Section 147Section 148Section 69

Rs.43,00,000/- and had paid advance of Rs.5,00,000/- on 06.10.2011. The Assessing Officer (AO) made addition of Rs.43,00,000/- as unexplained investment u/s. 69 of the Act. The aforesaid addition was based on receipt dated 06.10.2011 which was allegedly issued by one Shri Rajesh Kumar

Pushpanjali Constructions Private Limited, Pushpanjali Palace, Dehli Gate, Agra vs. DCIT, Cen Cir Ghaziabad

In the result appeal filed by the assessee is partly allowed

ITA 1001/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Ms. Amisha S. Gupt, CITDR

Section 143(3)Section 153ASection 153CSection 153DSection 69C

above, the Learned Assessing Officer has erred in law and on facts in making addition of Rs.12,55,00,000/- on account of unexplained investment u/s 69C of the Income Tax Act, 1961 without any proper legal basis, evidence or material on record, hence, liable to be deleted.” With regard ... unexplained money includible in assessee’s income - Held, yes Section 69, read with section 132(4A), of the Income-tax Act, 1961 - Unexplained investment - Assessment year 1985-86 - Whether in view of facts mentioned under above head "Unexplained money", document which was found at time of search and which

Ram Lakhan Dwivedi, Maihar vs. Income Tax Officer- Ward 1, Satna

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

ITA 180/JAB/2024[2019-20]Status: DisposedITAT Jabalpur18 Sept 2025AY 2019-20

Bench: Shri Kul Bharatassessment Year: 2019-20 Ram Lakhan Dwivedi V. Income Tax Officer 139, Rohaniya Khurd, Pakaria, Ward-1, Satna Distt-Maihar-485773. Income Tax Office, Civil Lines Chowk, Satna- 485001. Pan:Exmpd6359C (Appellant) (Respondent) Appellant By: Ms. Apoorva Garg, Ca Shri Kng Pillai, Advocate Respondent By: Shri N. M. Prasad , Sr. Dr-1 Date Of Hearing: 17 09 2025 Date Of Pronouncement: 18 09 2025 O R D E R

For Appellant: Ms. Apoorva Garg, CAFor Respondent: Shri N. M. Prasad , Sr. DR-1

Section 115BSection 144Section 147Section 148Section 234ASection 234BSection 271ASection 69A

assessee had made only term deposit to the extent of Rs.7,00,000/-. Thus, the total sum of Rs.7,24,417/- was treated as unexplained investment and added to the income of the assessee ex parte to the assessee. Aggrieved by this, the assessee preferred appeal before

Priyesh Singhania, Raipur vs. DCIT, Circle-1(1), Raipur

In the result, appeal of the assessee is allowed

ITA 462/RPR/2025[2017-18]Status: DisposedITAT Raipur18 Sept 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhury & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.462/Rpr/2025 "नधा"रण वष" / Assessment Year : 2017-18 Priyesh Singhania 730/1, Radha Kunj, Opposite Vip Guest House, Pahuna, Shankar Nagar Main Road, Raipur (C.G.)-492 001 Pan: Aoups7838A ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Circle-1(1), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Mahendra Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 10Section 143(1)Section 143(1)(a)Section 154Section 194D

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

Musaddilal Mansaram Infrastructure Pvt. Ltd., Bilaspur vs. Income Tax Officer, Ward-1(1), Bilaspur

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

ITA 160/RPR/2025[2015-16]Status: DisposedITAT Raipur18 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 149Section 149(1)(a)Section 151Section 153CSection 50C(2)Section 56(2)(vii)

unjustified and deserves to be deleted. 9. The Ld. AO erred in making an addition of Rs.75,92,450 u/s 69 for alleged unexplained investments, and the CIT(A) wrongly confirmed Rs. 65,08,900 u/s 56(2)(vii)(b), ignoring the fact that the lands were held as stock

Income Tax Officer-1(1), Bilaspur vs. Musaddilal Mansaram Infrastructure Pvt. Ltd., Bilaspur

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

ITA 153/RPR/2025[2015-16]Status: DisposedITAT Raipur18 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 149Section 149(1)(a)Section 151Section 153CSection 50C(2)Section 56(2)(vii)

Mithilesh Jagdeo Singh Pawar, Amravati vs. ITO Ward-5, Amravati

ITA 70/NAG/2025[2017-18]Status: DisposedITAT Nagpur18 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Mr. Mithilesh Jagdeo Singh Ito Ward-5 Pawar, Besides Dps, Vs. Ghatladki, Chandur Bazar, Saturna Road, Maharashtra - 444720. Maharashtra - 444605. Pan: Bpfpp6167L (Appellant) (Respondent) Present For: Assessee By : Ms. Mrudul Bhusari, Ld. Adv {Ld. Amicus Curie} Revenue By : Shri Surjit Kumar Saha, Ld. Sr. Dr Date Of Hearing : 26.06.2025 Date Of Pronouncement : 09.2025 O R D E R Per : Narender Kumar Choudhry:

For Appellant: Ms. Mrudul Bhusari, Ld. AdvFor Respondent: Shri Surjit Kumar Saha, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(40)Section 250Section 69A

reopening of the case. The AO though considered the said claim of the Assessee but ultimately made the addition of Rs.16,43,600/- as unexplained investment u/s 69A of the Act. 6. The Assessee, being aggrieved, challenged the said addition before the Ld. Commissioner, however, despite of sending four notices

Pratik Yogesh Jaiswal, Yavatmal vs. ITO Ward -1, Yavatmal

In the result, Assessee’s appeal is allowed for statistical purposes

ITA 169/NAG/2025[2016-17]Status: DisposedITAT Nagpur18 Sept 2025AY 2016-17

Bench: Shri Narender Kumar Choudhrypratik Yogesh Jaiswal, Ito, Ward-1, Yavatmal. Chhoti Gujri Road, Itwara Vs. Chowk, Yavatmal-445001. Pan: Asrpj 7342 K (Appellant) (Respondent)

For Appellant: Shri P.M. Gandhi, Ld. CAFor Respondent: Shri Surjit Kumar Saha, Ld. Sr.D.R

Section 143(3)Section 250

Assessing Officer (AO), vide assessment order dated 14/12/2018 u/sec. 143(3) of the Act, has made the additions of Rs. 12,71,730/- being ‘unexplained investment’ and Rs.3,63,000/- being ‘disallowance of expenses’ in absence of documentary evidences, such as, bills and vouchers, bank statements evidencing payments

Om Prakash Gupta, Sawai Madhopur vs. DCIT Central Circle -1, Jaipur

ITA 400/JPR/2025[2018-19]Status: DisposedITAT Jaipur18 Sept 2025AY 2018-19

For Appellant: Shri Tarun Mittal, CA &For Respondent: Shri Rajesh Ojha, CIT-DR &

Section 115BSection 153ASection 69

assessment u/s 153A for the year under appeal thus the deposits made in the bank account of Shri Ram Singh cannot be treated as unexplained investment per se and by no stretch of imagination can it be treated as unexplained investment made by the assessee and therefore, the same deserves ... action of ld. AO in making addition of Rs.16,09,07,018/- by alleging the same as investment in benami properties and thus unexplained investment. Appellant prays that addition has been made solely on the basis of statements of Sh. Ram Singh Meena , which stood retracted (and thus have

Om Prakash Gupta, Sawai Madhopur vs. DCIT Central Circle -1, Jaipur

The appeals of the assessee are disposed off as under :

ITA 399/JPR/2025[2017-18]Status: DisposedITAT Jaipur18 Sept 2025AY 2017-18

For Appellant: Shri Tarun Mittal, CA &For Respondent: Shri Rajesh Ojha, CIT-DR &

Section 115BSection 153ASection 69

Om Prakash Gupta, Sawai Madhopur vs. DCIT Central Circle -1, Jaipur

ITA 398/JPR/2025[2016-17]Status: DisposedITAT Jaipur18 Sept 2025AY 2016-17

For Appellant: Shri Tarun Mittal, CA &For Respondent: Shri Rajesh Ojha, CIT-DR &

Section 115BSection 153ASection 69

assessment u/s 153A for the year under appeal thus the deposits made in the bank account of Shri Ram Singh cannot be treated as unexplained investment per se and by no stretch of imagination can it be treated as unexplained investment made by the assessee and therefore, the same deserves ... action of Id. AO in making addition of Rs. 16,09,07,018/- by alleging the same as investment in benami properties and thus unexplained investment. Appellant prays that addition has been made solely on the basis of statements of Sh. Ram Singh Meena , which stood retracted (and thus have

Om Prakash Gupta, Sawai Madhopur vs. DCIT Central Circle -1, Jaipur

ITA 397/JPR/2025[2015-16]Status: DisposedITAT Jaipur18 Sept 2025AY 2015-16

For Appellant: Shri Tarun Mittal, CA &For Respondent: Shri Rajesh Ojha, CIT-DR &

Section 115BSection 153ASection 69

assessment u/s 153A for the year under appeal thus the deposits made in the bank account of Shri Ram Singh cannot be treated as unexplained investment per se and by no stretch of imagination can it be treated as unexplained investment made by the assessee and therefore, the same deserves ... action of Id. AO in making addition of Rs. 16,09,07,018/- by alleging the same as investment in benami properties and thus unexplained investment. Appellant prays that addition has been made solely on the basis of statements of Sh. Ram Singh Meena , which stood retracted (and thus have