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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

Varis Kishor Rupabhinda, Mumbai vs. Asst. Commissioner of Income Tax, Central Circle-4(3), Mumbai

In the result, ITA No. 3379/Mum/2025 is partly allowed for

ITA 4111/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Sept 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Bleι.Τ.Α. No. 3379 & 4111/Mum/2025

For Appellant: Asst. Commissioner ofFor Respondent: Ms. Kavita P. Kaushik, Sr. D/R
Section 143(2)Section 143(3)Section 147Section 68Section 69Section 69A

facts and circumstances of the case and in Law, Ld. CIT(A) erred in confirming the addition u/s.69 r.w.s.115BBE of alleged unexplained investment in mutual funds of Rs.15,55,000/-; 3.0 On facts and circumstances of the case and in Law, Ld. CIT(A) erred in confirming the addition u/s.69A ... without prejudice manner, erred in confirming the addition u/s.68 of alleged cash deposits made in bank account of Rs.70,000/- and of alleged unexplained investment in mutual funds of Rs.15,55,000/-; 5.0 The Ld. CIT(A) ought to have adopted the concept of real income and followed the assessment

Vicky Bipin Gala, Mumbai vs. ITO 41(1)(5), Mumbai

In the result, the appeal of the assesse bearing ITA No

ITA 3739/MUM/2025[2013-14]Status: DisposedITAT Mumbai04 Sept 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjeevicky Bipin Gala Vs Ito Ward-41(1)(5), Mumbai 124/8, 1St Floor, Block No.8, Kautilya Bhavan, Bkc, Kurla-400051 Vatsalganga Bldg, Plot No.124 Road No.24A, Sion (West), Mumbai-400 022 Pan: Agxpg4830F Appellant Respondent

For Appellant: Shri Dharan GandhiFor Respondent: Ms. Kavitha Kaushik (SR DR)
Section 115BSection 147Section 250Section 69

submitted that the addition of Rs.95,00,000/- was made under section 69 read with section 115BBE of the Act, treating the same as unexplained investment, and consequentially taxed under section 115BBE. Being aggrieved, the assessee preferred an appeal before the Ld. CIT(A). 3. It was argued that

Varis Kishorchandra Rupabhinda, Mumbai vs. Asst. Commissioner of Income Tax, Central Circle-4(3), Mumbai

In the result, ITA No. 3379/Mum/2025 is partly allowed for statistical purposes and ITA No

ITA 3379/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Sept 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Anikesh Banerjee, Hon'Bleι.Τ.Α. No. 3379 & 4111/Mum/2025

For Appellant: Shri Prakash Jhunjhunwala, A/RFor Respondent: Ms. Kavita P. Kaushik, Sr. D/R
Section 143(2)Section 143(3)Section 147Section 68Section 69Section 69A

facts and circumstances of the case and in Law, Ld. CIT(A) erred in confirming the addition u/s.69 r.w.s.115BBE of alleged unexplained investment in mutual funds of Rs.15,55,000/-; 3.0 On facts and circumstances of the case and in Law, Ld. CIT(A) erred in confirming the addition u/s.69A ... without prejudice manner, erred in confirming the addition u/s.68 of alleged cash deposits made in bank account of Rs.70,000/- and of alleged unexplained investment in mutual funds of Rs.15,55,000/-; 5.0 The Ld. CIT(A) ought to have adopted the concept of real income and followed the assessment

Pavanchandra Chitfunds Pvt Ltd, Guntur vs. Assistant Commissioner of Income Tax, Circle-2(1), Guntur

ITA 375/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam03 Sept 2025AY 2014-15

Bench: Us:

Section 143(1)Section 143(2)Section 143(3)

learned Commissioner of Income Tax (Appeals) is not justified in sustaining the addition of Rs.20,67,000 made by the assessing officer towards unexplained investment in property. 4. Any other ground that may be urged at the time of appeal hearing.” 2. Succinctly stated, the assessee company that is engaged ... records, determined the same at Rs. 20.57 lacs and called upon the assessee company to explain as to why an addition towards unexplained investment made for acquiring the said property during the subject year may not be made in its case. In reply, the assessee company expressed its inability

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 91/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh03 Sept 2025AY 2018-19

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

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

less 15% of the valuation done by the Ld. DVO by resort to the provisions of section 69B of the Act as unexplained investment and taxed as per the provisions of section 115BВЕ. 4. Briefly the facts of the case are that a search u/s 132 was conducted ... High Court in the case of M/s Avakar Infrastructure Company Vs. DCIT Circle -9 reported in 67 Taxmann.com page 39 has held as under :- Unexplained investment in property under 69 of the Act - Reassessment Whether while report of DVO may form foundation for reopening assessment, there must still be some

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 90/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh03 Sept 2025AY 2017-18

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

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

less 15% of the valuation done by the Ld. DVO by resort to the provisions of section 69B of the Act as unexplained investment and taxed as per the provisions of section 115BВЕ. 4. Briefly the facts of the case are that a search u/s 132 was conducted ... High Court in the case of M/s Avakar Infrastructure Company Vs. DCIT Circle -9 reported in 67 Taxmann.com page 39 has held as under :- Unexplained investment in property under 69 of the Act - Reassessment Whether while report of DVO may form foundation for reopening assessment, there must still be some

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Homelife Buildcon Pvt. Ltd., Ludhiana

In the result, appeal of the Department is dismissed

ITA 190/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh03 Sept 2025AY 2019-20

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 190/Chd/2025 निर्धारण वर्ष / Assessment Years : 2019-20 The Dy. CIT Central Circle-1 Ludhiana बनाम Homelife Buildcon Pvt. Ltd. Sunview Enclave, Ayali Kalan, Ludhiana, Punjab-142027 स्थायी लेखा सं./ PAN NO: AABCH5690M अपीलार्थी/ Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से/Assessee by : Shri Sudhir Sehgal, Advocate राजस्व की ओर से / Revenue by : Shri Manav Bansal, CIT, DR सुनवाई की तारीख / Date of

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 132Section 147

justified in deleting the addition of Rs. 9, 87, 62, 864/-made by the A.O on account of unexplained investment made for the purchase of agriculture lands from M/s Trimurti Homes Private Limited on the basis of seized documents pertains to other assessment year? Whether upon facts and circumstances

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Balwinder Singh, Ludhiana

In the result, Revenue appeal is dismissed and Assessee’s appeal is allowed

ITA 188/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh03 Sept 2025AY 2022-23

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 188/Chd/2025 निर्धारण वर्ष / Assessment Years : 2022-23 The Dy. CIT Central Circle-1 Ludhiana बनाम Balwinder Singh Kothi No. 1 Royal Palm Country Homes, Ayali Khurd, Ludhiana -141001, Punjab स्थायी लेखा सं./ PAN NO: ACFPS3514G अपीलार्थी/Appellant प्रत्यर्थी / Respondent Cross Objection No. 7/Chd/2025 In आयकर अपील सं. / ITA No. 188/Chd/2025 निर्धारण वर्ष / Assessment Years : 2022-23 Balwinder Singh Kothi No

For Appellant: Shri Sudhir Sehgal, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132(4)Section 69

justified to deleted the addition of Rs.77,27,500/- made by the A.O on account of unexplained investment for purchase of SCO on the basis of logical & rational extrapolation based on evidences ? 2. Whether upon facts and circumstances of the case and in law, the valuation report by valuer, various ... search and seizure operations at the business premises of Homelife Buildcon Pvt. Ltd. and the assessee on 16.11.2021. 4. The facts leading to the unexplained investment in the purchase of SCO have been discussed by the AO in para 4 of his order. The assessee had purchased one SCO from

Afi Feed Industries, Khanna vs. Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana

In the result, the appeal of the assessee is to be allowed

ITA 127/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh03 Sept 2025AY 2016-17

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 127, 90 & 91 /Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2016-17, 2017-18 & 2018-19 AFI Feed Industries Shop No. 13, Khanna City Centre, G.T. Road, Ground Floor, Bolck-C, Khanna, Punjab-141401 स्थायी लेखा सं./PAN NO: ABDFA5916B अपीलार्थी/Appellant निर्धारिती की ओर से/Assessee by : राजस्व की ओर से / Revenue by : बनाम The DCIT Central Circle-l Ludhiana प्रत्यर्थी / Respondent Shri Ashwani Kumar, Ms. Deepali

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,C.A’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 132Section 133ASection 148Section 250Section 69B

less 15% of the valuation done by the Ld. DVO by resort to the provisions of section 69B of the Act as unexplained investment and taxed as per the provisions of section 115BВЕ. 4. Briefly the facts of the case are that a search u/s 132 was conducted ... High Court in the case of M/s Avakar Infrastructure Company Vs. DCIT Circle -9 reported in 67 Taxmann.com page 39 has held as under :- Unexplained investment in property under 69 of the Act - Reassessment Whether while report of DVO may form foundation for reopening assessment, there must still be some

Dy. Commissioner of Income Tax, Central Circle-3, Ludhiana vs. Gurdip Cycle Industries, Dashmesh Nagar, Ludhiana

In the result Revenue appeal in A

ITA 1207/CHANDI/2024[2022-23]Status: DisposedITAT Chandigarh03 Sept 2025AY 2022-23

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA Nos.1205 To 1207/Chd/ 2024 निर्धारण वर्ष / Assessment Years : 2019-20, 2020-21 & 2022-23 बनाम The Dy. CIT Central Circle-3 Ludhiana Gurdeep Cycle Industries 370, St. No. 1, Link Road Dashmesh Nagar, Ludhiana-141003, Punjab स्थायी लेखा सं. / PAN NO: AAAFG9508M प्रत्यर्थी / Respondent अपीलार्थी/Appellant Cross Objection Nos.23 To 25/Chd/2025 In (आयकर अपील सं. / ITA Nos.1205 To 1207/Chd/ 2024) निर्धारण वर्ष / Ass

For Appellant: Shri Sudhir Sehgal, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 147Section 153C

Ganesh Builders. 3). a).That the Ld. CIT(A) has erred in confirming the addition of Rs.8, 20,494/-on account of alleged unexplained investment in excess stock u/s 69 of the Act. b). That the CIT(A) has failed to appreciate that the said addition was not sustainable, since ... being adjudicated. 15. There is independent ground of appeal in Cross Objection for Asstt. Year 2022-23 with regard to confirmation of addition of unexplained investment in excess stock to the tune of Rs. 8,20,494/- u/s 69. The facts are that during the course of search and seizures

Dy. Commissioner of Income Tax, CC-3, Ludhiana vs. Gurdip Cycle Industries, Dashmesh Nagar, Ludhiana

In the result Revenue appeal in A

ITA 1206/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh03 Sept 2025AY 2020-21
For Appellant: Shri Sudhir Sehgal, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 147Section 153C

Ganesh Builders. 3). a).That the Ld. CIT(A) has erred in confirming the addition of Rs.8, 20,494/-on account of alleged unexplained investment in excess stock u/s 69 of the Act. b). That the CIT(A) has failed to appreciate that the said addition was not sustainable, since ... being adjudicated. 15. There is independent ground of appeal in Cross Objection for Asstt. Year 2022-23 with regard to confirmation of addition of unexplained investment in excess stock to the tune of Rs. 8,20,494/- u/s 69. The facts are that during the course of search and seizures

Dy. Commissioner of Income Tax, CC-3, Ludhiana vs. Gurdip Cycle Industries, Ludhiana

In the result Revenue appeal in A

ITA 1205/CHANDI/2024[2019]Status: DisposedITAT Chandigarh03 Sept 2025

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA Nos.1205 Το 1207/Chd/ 2024 निर्धारण वर्ष / Assessment Years : 2019-20, 2020-21 & 2022-23 | | बनाम | | | :--- | :---: | :--- | | The Dy. CIT Central Circle-3 Ludhiana | | Gurdeep Cycle Industries 370, St. No. 1, Link Road Dashmesh Nagar, Ludhiana-141003, Punjab | स्थायी लेखा सं. / PAN NO: AAAFG9508M अपीलार्थी/Appellant | | प्रत्यर्थी / Respondent Cross Objection Nos.23 Το 25/Chd/2025 In (आयकर अपील सं. / ITA Nos

For Appellant: Shri Sudhir Sehgal, Advocate &For Respondent: Shri Manav Bansal, CIT, DR
Section 147Section 153C

Ganesh Builders. 3). a).That the Ld. CIT(A) has erred in confirming the addition of Rs.8, 20,494/-on account of alleged unexplained investment in excess stock u/s 69 of the Act. b). That the CIT(A) has failed to appreciate that the said addition was not sustainable, since ... being adjudicated. 15. There is independent ground of appeal in Cross Objection for Asstt. Year 2022-23 with regard to confirmation of addition of unexplained investment in excess stock to the tune of Rs. 8,20,494/- u/s 69. The facts are that during the course of search and seizures

Sudhir Ramchandraji Mantri, Jalna vs. Assessment Unit, Income Tax Department, Jalna

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

ITA 526/PUN/2025[2022-23]Status: DisposedITAT Pune03 Sept 2025AY 2022-23

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Respondent: Appellant by None
Section 143(3)Section 250Section 44ASection 69

available on record. 2 Sudhir Ramchandraji Mantri 3. The sole grievance of the assessee is that ld.CIT(A) erred in confirming the addition for unexplained investment amounting to Rs.44.00 lakh. 4. Brief facts of the case are that the assessee is an individual and for A.Y. 2012-13 income ... source of investment on which interest income has been received and concluded the proceedings making addition of Rs.44.00lakh in the hands of assessee towards unexplained investment, 5. Aggrieved assessee preferred appeal before ld.CIT(A) but failed to succeed. Now the assessee is in appeal before this Tribunal. 6. We have

Thucanaickenpalayam Marannan Manoharan, Erode vs. ITO, Ward-2(4), Erode

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

ITA 824/CHNY/2025[2016-17]Status: DisposedITAT Chennai03 Sept 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 824/Chny/2025 धनिाारण वर्ा / Assessment Year: 2016-17 Thuckanaickenpalayam Marannan Income Tax Officer, Manoharan, Vs. Ward 2(1), Erode. 144, T.N. Palayam Gobi, Erode – 638 506, Tamil Nadu. [Pan: Aaipm-5470-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. P.M Kathir, Advocate & Shri. G. Akash , Advocate प्रत्यथी की ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 28.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 03.09.2025

For Appellant: Shri. P.M Kathir, Advocate and Shri. G. Akash , AdvocateFor Respondent: Ms. Anitha, Addl.CIT
Section 69

erred in confirming the addition made. :-2-: ITA. No: 824/Chny/2025 4) The CIT(A) erred in upholding the addition of Rs.18,84,065/- as unexplained investment u/s. 69 of the Act. 5) The Appellant having provided the source for the investment, the CIT(A) erred in upholding ... erroneous addition. 6) Any other ground/s that may be raised at the time of hearing. 3. The assessee has challenged the addition of unexplained investment of Rs.18,84,065/- made by the AO u/s.69, being the increase in capital of the appellant in his partnership firm. 4. The facts

Chanda Singh, Katihar vs. ACIT, Central Circle-3, Patna

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

ITA 127/PAT/2025[2019-20]Status: DisposedITAT Patna02 Sept 2025AY 2019-20

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 153CSection 250Section 69

consequently addition pronounced by the said order is fit to be reversed. B) The Learned AO & CIT (A) has not appreciated the fact that unexplained investment clause of section 69 of the Income Tax Act, 1961 does not attract unless there is a finding of not recording of such transactions ... assessing officer to compute the income of the assessee, in the instant case where a sale deed was brought into question, the addition (alleged unexplained investment) finds its mention therein, that in itself is a fair indication that the assessee had purchased the land at that value, and from

Salvantsingh Swarupsingh Pallu, Vadodara vs. ITO, Ward 1(1)(1), Vadodara

In the result, the appeal of the assessee is allowed

ITA 949/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad02 Sept 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalsalvantsingh Swarupsingh Pallu, The Income Tax Officer, Vs. A1, 204, Mangal Marvel Ward 1(1)(1), Apartment, Tarsali, Vadodara. Vadodara-390009 [Pan : Alqpp 5330 F] (Appellant) .. (Respondent) Appellant By : Shri Sanket Bakshi, Ar Respondent By: Shri Rajenkumar M. Vasavda, Sr Dr Date Of Hearing 12.08.2025 Date Of Pronouncement 02.09.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri Sanket Bakshi, ARFor Respondent: Shri Rajenkumar M. Vasavda, Sr DR
Section 147Section 250Section 69

learned Assessing Officer erred in law and on facts in treating the cash deposit amounting to Rs.6,78,400/- as unexplained investment under Section 69 of the Income Tax Act, 1961, without properly appreciating the evidences submitted regarding the availability of sources including agricultural Income, past savings, family income ... found that cash deposits of Rs.6,78,400/- remained unexplained. Accordingly, he added the said amount u/s. 69 of the Act, treating it as unexplained investment. 4. The assessee filed appeal before the CIT(A). However, the Ld. CIT(A), noting non-compliance and lack of supporting documents, confirmed

Mohammad Husain, Muzaffarnagar vs. ITO, Muzaffarnagar

Appeal is partly allowed

ITA 1772/DEL/2025[2012-13]Status: DisposedITAT Delhi02 Sept 2025AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahmanita No. 1772/Del/2025 : Asstt. Year : 2012-13 Mohd. Husain, Prop. Vs Income Tax Officer, Vill.- Bajheri, Ward-1(3), Muzaffarnagar, U.P.-251001 Muzaffarnagar, U.P. (Appellant) (Respondent) Pan No. Acaph9956L Assessee By : None Revenue By : Sh. Pradumna Kumar Singh, Sr. Dr Date Of Hearing: 02.09.2025 Date Of Pronouncement: 02.09.2025 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2012-13, Arises Against The Addl./Jcit(A)-7, Mumbai’S Din & Order No. Itba/Apl/S/250/2024-25/1072735985(1) Dated 03.01.2025, In Proceedings U/S 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Pradumna Kumar Singh, Sr. DR
Section 144

representative vehemently argues during the course of hearing that both the lower authorities have rightly assessed an amount of Rs.7,82,000/- as an unexplained investment in his hands, in assessment order 2 Mohammad Husain dated 19.12.2019 and upheld in the lower appellate discussion. He further takes us to para

Urmila Kurariya (L/H of Late Shri Ganga Prasad Kurariya), Jabalpur vs. Income Tax Officer, Jabalpur

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

ITA 69/JAB/2025[2010-11]Status: DisposedITAT Jabalpur01 Sept 2025AY 2010-11

Bench: Shri Anadee Nath Misshra

Section 144Section 147Section 148Section 253(3)

determined the total income of the assessee at Rs.10,04,440/- by making addition of Rs.8,31,538/- as unexplained investment in property. Being aggrieved, the assessee filed appeal in the office of learned CIT(A). Vide order dated 05/06/2023, the assessee’s appeal was dismissed by the learned

Dineshwar Prasad, Sarvadya Kamla Apartment, Boring Road vs. Deputy Commissioner of Income Tax, Circle-4, Patna, Not Known

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

ITA 250/PAT/2025[2014-15]Status: DisposedITAT Patna01 Sept 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.250/Pat/2025 Assessment Year: 2014-15 Dineshwar Prasad.………………………. …………………....Appellant Sarvadya Kamla Apartment, An Path, North S K Puri, Boring Road, Patna - 800013. [Pan: Acwpp8473C] Vs. Dcit, Circle-4, Patna…..…..……………..………………….…..... Respondent Appearances By: Shri S.S.P Singh, Fca Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 21.02.2023 Passed By The Nfac, Delhi Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 749 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 250Section 69

bank account. Due to non-compliance, the Assessing Officer treated Rs.21,31,000/- out of total cash deposits of Rs.56,81,000/- as unexplained investments u/s 69 of the Act and added the same to the total income of the assessee. 4. Aggrieved by the order of the Assessing Officer

The ACIT, Central Circle-2, Rajkot vs. Shri Bhagvanji Prabhubhai Amrutiya, Morbi

In the result, cross objection filed by the assessee, ( in CO No

ITA 142/RJT/2021[2019-20]Status: DisposedITAT Rajkot29 Aug 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

For Appellant: Shri Mehul Ranpura, ld.ARFor Respondent: Shri Sanjay Punglia, ld.CIT-DR
Section 133ASection 143(3)Section 37Section 69ASection 69B

case and in law, learned Commissioner (Appeals) erred in deleting the addition of Rs. 1,48,89,125/-made on account of unexplained investment u/s 69B of the I.T. Act. 5.On the facts and in the circumstances of the case and in law, learned Commissioner (Appeals) erred in ignoring ... this connection, we in addition to our earlier replies in the same issue further submit as under: As regard the allegation of unexplained investment in land of Rs. 1,48,89,125/- on the basis of alleged Satakhat (agreement) impounded during the survey action carried out at the office