“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

Shashi Infra Construction Pvt. Ltd., Lucknow vs. ITO, Lucknow

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

ITA 353/LKW/2023[2016-17]Status: DisposedITAT Lucknow11 Sept 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2016-17 Shashi Infra V. The Constructions Pvt Ltd Addl/Joint/Deputy/Asstt/Income 328B, 5Th Lane Rajendra Tax Officer, Lucknow Nagar, Lucknow-226004. National Faceless Assessment Centre Delhi Tan/Pan:Aaucs5802M (Appellant) (Respondent) Appellant By: Shri Saurabh Gupta, C.A. Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri Saurabh Gupta, C.AFor Respondent: Shri R. K. Agarwal, CIT(DR)

Section 144Section 144BSection 147Section 148Section 253(3)Section 694ASection 69A

assessee could not substantiate the source of investment of Rs 5,00,00,000/-against purchase of property, it is inferred that source of unexplained investment amounting to Rs 500,00,000/- has left to be taxed and escaped assessment for Α.Υ 2016-17* To summarise, the entire reasons ... assessee could not substantiate the source of Investment of Rs 5,00,00,000/- against purchase of property, it is inferred that source of unexplained Investment amounting to Rs 500,00,000/- has left to be taxed and escaped assessment for A.Y 2016-17" Your honour will observe that

Bharat Kumar, Chennai vs. ITO, Ncw-4(5), Chennai

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

ITA 784/CHNY/2025[2016-17]Status: DisposedITAT Chennai11 Sept 2025AY 2016-17

Bench: Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.784/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Bharat Kumar, Vs. The Income Tax Officer, No. 152, 10Th Street, Deber Nagar, Non Corporate Ward 4(5), Vyasarpadi 600 039,Chennai. Chennai 600 006. [Pan:Bfhpb6487D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R.S. Hithesh, Advocate For Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.09.2025 घोषणा की तारीख /Date Of Pronouncement : 11.09.2025 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.02.2025 Passed By The Addl/Jcit(A)-1, Bengaluru For The Assessment Year 2016-17. 2. The Ld. Ar Shri R.S. Hithesh, Advocate Placed On Record Memo Of Additional Ground & Requested To Take Up The Said Additional Ground As Preliminary Issue. After Hearing Both The Parties, I Am Inclined To Treat The Additional Ground As Preliminary Issue.

For Appellant: Shri R.S. Hithesh, Advocate for Shri D. Anand, AdvocateFor Respondent: Ms. V. Aswathy, JCIT

Section 133(6)Section 68Section 69

I.T.A. No.784/Chny/25 addition made by the Assessing Officer under section 69 of the Income Tax Act, 1961 [“Act” in short] as unexplained investment into one under section 68 of the Act as unexplained cash credit, thereby travelled beyond the scope of the assessment order and renders the impugned order unsustainable ... referred to para 8.5, 8.6 and 8.9 of the assessment order and argued that the Assessing Officer proceeded to make addition on account of unexplained investment under section 69 of the Act. Further, he referred to para 5.7 of the impugned order and submits that the ld. CIT(A) travelled

S Ramesh, Chennai vs. ITO, Ncw-22(5), Tambaram

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

ITA 1501/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1501/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2017-18 S. Ramesh, Income Tax Officer, No.2, Agaram Main Road, Vs. Non-Corp Ward-22(5), Selaiyur Tambaram. Chennai– 600 073. [Pan:Agepr-8695-J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Ms. Parvatha Varthini, Advocate. प्रत्यथी की ओर से/Respondent By : Shri. P.K. Senthil Kumar, Addl.Cit.

For Appellant: Ms. Parvatha Varthini, AdvocateFor Respondent: Shri. P.K. Senthil Kumar, Addl.CIT

Section 142(1)Section 143(2)Section 143(3)Section 68Section 69

dated 26.12.2019, by adding an amount of cash deposits made during the demonetization period in Savings Bank Account of Rs.5,85,000/- as unexplained investment u/s.69 of the Act and amount of cash deposit made in Current Account of Rs.22,56,500/- as unexplained cash credits u/s.68

ACIT, Central Circle 1(1), Bengaluru vs. Sunil Suresh, Bengaluru

In the result, appeal filed by the Revenue is dismissed

ITA 2168/BANG/2024[2020-21]Status: DisposedITAT Bangalore11 Sept 2025AY 2020-21

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2020-21 Acit, Vs. Shri. Sunil Suresh, Central Circle – 1(1), S-02, Skyline Apartment, Ieonard Lane, Bangalore. Richmond Town, Bangalore – 560 025, Karnataka. Pan : Akrps 0614 D Appellant Respondent Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Shri. Sankar Ganesh D, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 12.08.2025 Date Of Pronouncement : 11.09.2025

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Sankar Ganesh D, Addl. CIT(DR)(ITAT), Bangalore

Section 132Section 132(1)Section 132(4)Section 144(3)Section 69

passed by the DCIT, Central Circle – 1(1), Bangalore, on 28.03.2022 in which the AO has made addition of Rs.1,65,45,323/- as unexplained investment in jewellery under section 69 of the Act. During the course of search, various kinds of jewellery were found and seized. The list ... assessee in sworn statement under section 132 of the Act has stated that in the absence of documentary evidence, the unexplained investment in jewellery will be offered to tax. The AO noted that he has not filed any wealth tax return and the invoices produced do not match or identify

Bhavana Manoj Singh, Mumbai vs. Income Tax Officer Ward 24(1)(1), Mumbai

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

ITA 4581/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Sept 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailbhavana Manoj Singh, Flat No. 404, Kamal Apartment, Lokhandwala Complex, Opp. Rna Market, Azad Nagar, ............... Appellant Mumbai-400053. Pan : Bchps6429M V/S Income Tax Officer Ward 24(1)(1), ……………… Respondent Piramal Chambers, Mumbai – 400012. Assessee By : Shri Haridas Bhatt Revenue By : Shri Leyaqat Ali Aafaqui, Sr.Dr

For Appellant: Shri Haridas BhattFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.DR

Section 144BSection 147Section 250Section 69Section 69A

circumstances of the case, and in Law, the Income Tax Assessment Unit ("AO") erred adding Rs.71,00,000/- u/s 69 of the Act, as unexplained investments towards the payment made for purchase of property. B. On the facts and circumstances of the case and in law the AO failed

Ratan Jodharam Harchwani, Mumbai vs. Income Tax Officer War-2, Kalyan

In the result, the appeal of the assessee stands allowed on legal aspect

ITA 2650/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Sept 2025AY 2015-16

Bench: SHRI BEENA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 148ASection 149Section 254(1)Section 69

Learned Assessing Officer was not justified in treating the credit entries of Rs.4,36,05,730/- appearing in the Bank Account as the unexplained investment under section 69 of the Act and by making an addition of Rs.4,36,05,730/- to the total income. 5. The appellant craves leave ... complete the assessment on ex-parte basis u/s. 144. The assessment therefore has been completed on 20.03.2023 making an addition on account of unexplained investment u/s. 69 of the Act for the amount credited in the bank account of assessee for Rs. 4,36,05,730/-. 5. Aggrieved with

Ratan Jodharam Harchwani, Mumbai vs. Income Tax Office, Ward-2, Thane

In the result, the appeal of the assessee stands allowed on legal aspect

ITA 2649/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Sept 2025AY 2014-15

Bench: SHRI BEENA PILLAI (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 148ASection 149Section 254(1)Section 69

Rajesh Laxmichand Jain, Mumbai vs. ITO Ward 41(3)(3), Mumbai

ITA 1615/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Sept 2025AY 2016-17

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am Rajesh Laxmichand Jain Income Tax Office, Ward 41(3)(3) 188, Squarter Colony, Malwani Colony, Kautilya Bhavan, Bkc, 41-43, Vs. Malad West – 400095 Maharashtra, Bandra West, Mumbai 400051 India Pan/Gir No.: Adzpj4846K (Appellant) : (Respondent) Assessee By : Shri H D Save, Adv. Respondent By : Shri Annavaran Kasuri, Sr. Ar. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025 O R D E R Per Arun Khodpia, Am:

For Appellant: Shri H D Save, AdvFor Respondent: Shri Annavaran Kasuri, SR. AR

Section 142(1)Section 147Section 148Section 250Section 69

assessed income of Rs. 1,10,00,000/- treating the entire investment of Rs. 1,10,00,000/- in the property as unexplained investment u/s.69 of the Income Tax Act, 1961, in the absence of any sources and explanation of the investment in the said property. 2 Rajesh Laxmichand Jain

Balwant Siingh, Bathinda vs. Dcitacit(Cen)-2, Chandigarh

In the result, appeal of the Assessee is allowed

ITA 850/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh10 Sept 2025AY 2017-18

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM Balwant Singh आयकर अपील सं. / ITA No. 850/Chd/2024 निर्धारण वर्ष / Assessment Years : 2017-18 H.No. 93-94, Model Town, Bathinda Punjab-151001 स्थायी लेखा सं./ PAN NO: BZAPS9230A अपीलार्थी/ Appellant निर्धारिती की ओर से/Assessee by : राजस्व की ओर से/ Revenue by : सुनवाई की तारीख / Date of Hearing: उदघोषणा की तारीख/Date of Pronouncement : आदेश/Order PER KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR

Section 132Section 153A

erred in confirming the addition of Rs. 1300000/- made by the AO under the head Income from other sources on account of unexplained investment in plot No 3, Divine Enclave, Near Model Town, Phase 3, Part 2 Bhatinda. The order passed by the CIT(A) is contrary to the facts

Kwality Overseas Private Limited, Ludhiana vs. Deputy Commissioner of Income Tax, Ludhiana

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

ITA 553/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh10 Sept 2025AY 2012-13

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 553/Chd/2024 निर्धारण वर्ष / Assessment Years : 2012-13 Kwality Overseas Private Limited 863, Industrial Area-A, Ludhiana बनाम The DCIT Ludhiana स्थायी लेखा सं./ PAN NO: AABCK6381J अपीलार्थी/Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assessee by : Shri Ashwani Kumar, C.A राजस्व की ओर से / Revenue by : Shri Manav Bansal, CIT, DR सुनवाई की तारीख / Date of Hearing : 07/08/2025 उदघोषणा की तारीख/Date

For Appellant: Shri Ashwani Kumar, C.AFor Respondent: Shri Manav Bansal, CIT, DR

Section 144Section 147Section 250(6)Section 271(1)(b)Section 69Section 69A

imports and the source of bank deposits. A show-cause notice dated 23.11.2019 was also issued proposing additions of Rs.1,96,07,905/- as unexplained investment under Section 69 and Rs.5,81,11,290/- as unexplained money under Section 69A; however, no compliance was made. Accordingly, the AO completed

Lakhvir Kaur, Mohali vs. DCIT/ACIT(Cen)-2, Chandigarh

In the result, both the above appeals of the Assessee are

ITA 1165/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh10 Sept 2025AY 2021-22

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR

Section 143(3)Section 250(6)Section 65BSection 69C

loan. 5. That the CIT (A) has erred in confirming addition to the tune of Rs.34110/- made by the in respect of unexplained investment in jewelry. 5.1 That the CIT (A) has erred in confirming addition to the tune of Rs.34110/- on account of unexplained investment in jewelry without appreciating ... erred in making the impugned addition of Rs.4,02,605/- in the hands of appellant u/s 69 on account of unexplained investment in jewelry. 4.1 That on the faces and circumstances of the case and in laws the Ld. AO has totally erred in making such impugned addition of Rs.4

Lakhvir Kaur, Mohali, Chandigarh vs. DCIT/ACIT(Cen)-2 Chd, Chandigarh

In the result, both the above appeals of the Assessee are

ITA 1164/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh10 Sept 2025AY 2020-21

For Appellant: Shri Rohit Kapoor, Advocate &For Respondent: Shri Manav Bansal, CIT, DR

Section 143(3)Section 250(6)Section 65BSection 69C

Mb Akkaiah and Company, Miryalguda vs. ACIT., Circle-7(1), Hyderabad

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

ITA 1133/HYD/2025[2017-18]Status: DisposedITAT Hyderabad10 Sept 2025AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: -None-For Respondent: Sri Madan Mohan Meena, Sr. AR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

above, the Assessing Officer noted that, the amount of Rs.51,14,000/- deposited in the bank account during the demonetization period is treated as unexplained investment and added to the total income of the assessee vide order dated 25.12.2019 passed u/sec.143(3) of the Income Tax Act, 1961. 3. Aggrieved ... evident from para-3 of the order. However, the Assessing Officer without considering the same made the impugned addition of Rs.51,14,000/- as unexplained investment u/sec.68 of the Act. During the course of appellate proceedings before the learned CIT(A), despite issue of notices on several occasions, the assessee

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Deepankar Jain, Ludhiana

In the result appeal of the Department is dismissed and Cross

ITA 183/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh09 Sept 2025AY 2022-23

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate &For Respondent: Shri Manav Bansal, CIT, DR

Section 143(3)Section 148Section 148BSection 65BSection 69

justified in deleting the addition to Rs. 1,12,50,000/- made by the AO on account of unexplained investment u/s 69 of the Act on the basis of logical and rational based on evidences?. 2. Whether upon facts and circumstances of the case, the Ld. CIT(A) was justified ... department appeal is about the deletion of addition of Rs. 1,12,50,000/- made by the Assessing Officer on account of unexplained investment u/s 69, based on digital device of Sh. Deepankar Jain. The facts have been discussed by the Assessing Officer from page 2 to page

Renu Vinod Kaushal, Vadodara vs. The ITO, Ward-1(2)(2), Vadodara

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

ITA 1949/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad09 Sept 2025AY 2012-13

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2012-13

Section 144Section 147Section 148Section 44ASection 68Section 69A

explained that the same represented the receipts of business of transportation. As regarding addition of Rs.10,00,000/- in respect of unexplained investments, the Ld. AR submitted that the investment was made from the bank account of the assessee’s daughter Ms. Tinku Ajay Shah and the assessee had produced ... nominee of the said account. Considering the evidence brought on record by the assessee, the addition of Rs.10,00,000/- in respect of unexplained investment in bonds/debentures is deleted. The ground of the assessee is allowed. 10. In the result, the appeal of the assessee is partly allowed. Order pronounced

Bibhu Prasad Sahoo, Puri vs. Income Tax Officer Ward 62(3), Kolkata

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

ITA 21/KOL/2025[2017-2018]Status: DisposedITAT Kolkata09 Sept 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

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

Further, the AO did not mention the corresponding section under which these additions had been made. Since the cash deposits are nothing but his unexplained investment, the addition is confirmed as unexplained investment u/s 69 of the Act and in view of the above, the appeal of the appellant

Rajiv Venkatpathi Gowda, Bengaluru vs. DCIT, Central Circle-2(1), Bangalore

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

ITA 671/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Sept 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2015-16

For Appellant: NoneFor Respondent: Shri Subramanian .S, JCIT-DR

Section 132(4)Section 153CSection 17Section 234ASection 69

verified the bank statements and found that the said credits are not from M/s. MG Charitable Trust and therefore treated the said credits as unexplained investments u/s. 69 of the Act. Similarly, the AO had disallowed the payment of premium to LIC on the ground that the said payment ... bank account of the assessee. The assessee had not objected for taxing the said amount and therefore the said payment was treated as unexplained investment u/s. 69 of the Act. 4. As against the said order, the assessee filed an appeal before the Ld.CIT(A)-15, Bengaluru. The Ld.CIT

Assistant Commissioner of Income Tax, Kalyan vs. Jamini Industries Private Limited, Badlapur

In the result, the appeals filed by the revenue bearing ITA Nos 6081 &

ITA 6082/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Sept 2025AY 2015-16

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Akkal DhudhewalaFor Respondent: Ms. Kavitha Kaushik (SR DR)

Section 115JSection 143(2)Section 143(3)Section 250Section 263Section 27Section 68

basis of the report, Ld.AO added back the loan amount of Rs.4.15 crore and further, the interest payment on bogus loan was treated as unexplained investment which is also added back amount to Rs.34,58,630/-. She further stated that the loan creditors have submitted the documents in relation

Assistant Commissioner of Income Tax, Kalayn vs. Jamini Industries Private Limited, Badlapur

In the result, the appeals filed by the revenue bearing ITA Nos 6081 &

ITA 6081/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 Sept 2025AY 2014-15

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Akkal DhudhewalaFor Respondent: Ms. Kavitha Kaushik (SR DR)

Section 115JSection 143(2)Section 143(3)Section 250Section 263Section 27Section 68

Sainik Co Operative House Building Society Limited, Jammu and Kashmir vs. ITO Ward 1(1), Jammu

In the result the appeal of the assessee is allowed on the legal issue as indicated above

ITA 698/ASR/2024[2013-14]Status: DisposedITAT Amritsar08 Sept 2025AY 2013-14

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Hybrid Hearing) I.T.A. No. 698/Asr/2024 Assessment Year: 2013-14

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

addition made by the AO u/s 69A without appreciating that the provisions of section 69A can only be invoked in the case of unexplained investment not recorded in the books of account and not on account of cash deposited in bank. I.T.A. No. 698/Asr/2024 3 Assessment Year