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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

Zakir Abdulkarim Naik, Mumbai vs. AO, Income Tax

In the result, all these appeals are dismissed

ITA 4780/MUM/2023[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: NONEFor Respondent: Shri Satya Pal Kumar, CIT-DR a/w
Section 142(1)Section 144Section 147Section 148Section 68Section 69

Abdulkarim Naik (batch appeals) Rs. 1,43,64,560/-wherein the AO brought to tax unexplained deposits in the bank accounts u/s 68 and unexplained investments u/s 69 of the Act. It was submitted that similar fact exists for other assessment years wherein the notices u/s 148 were served ... assessment proceedings were completed u/s. 144 r.w.s. 147 of the Act wherein the AO brought to tax unexplained deposits, unexplained foreign remittances and unexplained investments and the assessed income was determined at Rs. 2,49,99,730/- for AY. 2011-12 vide order

Zakir Abdulkarim Naik, Mumbai vs. AO, Income Tax

In the result, all these appeals are dismissed

ITA 4779/MUM/2023[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: NONEFor Respondent: Shri Satya Pal Kumar, CIT-DR a/w
Section 142(1)Section 144Section 147Section 148Section 68Section 69

Abdulkarim Naik (batch appeals) Rs. 1,43,64,560/-wherein the AO brought to tax unexplained deposits in the bank accounts u/s 68 and unexplained investments u/s 69 of the Act. It was submitted that similar fact exists for other assessment years wherein the notices u/s 148 were served ... assessment proceedings were completed u/s. 144 r.w.s. 147 of the Act wherein the AO brought to tax unexplained deposits, unexplained foreign remittances and unexplained investments and the assessed income was determined at Rs. 2,49,99,730/- for AY. 2011-12 vide order

Zakir Abdulkarim Naik, Mumbai vs. AO, Income Tax

In the result, all these appeals are dismissed

ITA 4778/MUM/2023[2010-11]Status: DisposedITAT Mumbai30 Jul 2025AY 2010-11

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: NONEFor Respondent: Shri Satya Pal Kumar, CIT-DR a/w
Section 142(1)Section 144Section 147Section 148Section 68Section 69

Abdulkarim Naik (batch appeals) Rs. 1,43,64,560/-wherein the AO brought to tax unexplained deposits in the bank accounts u/s 68 and unexplained investments u/s 69 of the Act. It was submitted that similar fact exists for other assessment years wherein the notices u/s 148 were served ... assessment proceedings were completed u/s. 144 r.w.s. 147 of the Act wherein the AO brought to tax unexplained deposits, unexplained foreign remittances and unexplained investments and the assessed income was determined at Rs. 2,49,99,730/- for AY. 2011-12 vide order

Urwashi Ranjan, Delhi vs. ITO Ward-2(2)(1), Ghaziabad

In the result, ground no. 3 of appeal is allowed

ITA 3541/DEL/2025[2012-13]Status: DisposedITAT Delhi30 Jul 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.3541/दिल्ली/2025 (नि.व. 2012-13)

For Respondent: Shri Abhishek Jain, Chartered Accountant

discharge her onus to prove genuineness of the loan transaction. The AO has erred in making addition of Rs.12,52,650/-on account of unexplained investments. 4. Per contra, Ms. Sudha Gupta representing the department vehemently defended the impugned order and prayed for dismissing appeal of the assessee ... discharged her onus in proving source of funds for purchase of the property. Hence, addition of Rs. 12,52,650/- on account of unexplained investment is without any merit. Hence, the addition is deleted. 6. In the result, ground no. 3 of appeal is allowed. 7. The other peripheral issues

DCIT Central Circle-25, Delhi vs. Strategic Credit Capital Pvt. Ltd., Delhi

ITA 438/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2017-18 Strategic Credit Capital Pvt. Ltd., Vs Acit, A-49, Engine House, Central Circle-25, Mathura Road, Delhi. Mohan Cooperative Indus. Estate, Delhi – 110 055. Pan: Aaack4532C Assessment Year: 2017-18 Acit, Vs. Strategic Credit Capital Pvt. Ltd., Central Circle-25, A-49, Engine House, Delhi Mathura Road, Mohan Cooperative Indus. Estate, Delhi – 110 055. Pan: Aaack4532C (Assessees) (Respondents) Assessee By : None Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 02.07.2025 Date Of Pronouncement : 30.07.2025 Order Per Anubhav Sharma, Jm:

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 132Section 132(4)Section 150Section 68Section 69Section 69A

circumstances of the case and in law in directing AO to take into account the findings in the appellate order for considering amounts as unexplained investments for earlier assessment years overlooking that addition as unexplained investments under section 69 cannot be made of amount recorded in books of accounts ... legally justified in deleting the addition of Rs. 123,48,53,648/- 2 ITAs No.289 &438/Del/2022 made on account of unexplained investments without considering the fact emerged in the search proceeding and found in incriminating material. iii) Whether on the facts and circumstances of the case

Strategic Credit Capital Pvt. Ltd., Delhi vs. ACIT, Central Circle25, Delhi

ITA 289/DEL/2022[2017-18]Status: DisposedITAT Delhi30 Jul 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2017-18 Strategic Credit Capital Pvt. Ltd., Vs Acit, A-49, Engine House, Central Circle-25, Mathura Road, Delhi. Mohan Cooperative Indus. Estate, Delhi – 110 055. Pan: Aaack4532C Assessment Year: 2017-18 Acit, Vs. Strategic Credit Capital Pvt. Ltd., Central Circle-25, A-49, Engine House, Delhi Mathura Road, Mohan Cooperative Indus. Estate, Delhi – 110 055. Pan: Aaack4532C (Assessees) (Respondents) Assessee By : None Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 02.07.2025 Date Of Pronouncement : 30.07.2025 Order Per Anubhav Sharma, Jm:

For Appellant: NoneFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 132Section 132(4)Section 150Section 68Section 69Section 69A

circumstances of the case and in law in directing AO to take into account the findings in the appellate order for considering amounts as unexplained investments for earlier assessment years overlooking that addition as unexplained investments under section 69 cannot be made of amount recorded in books of accounts ... legally justified in deleting the addition of Rs. 123,48,53,648/- 2 ITAs No.289 &438/Del/2022 made on account of unexplained investments without considering the fact emerged in the search proceeding and found in incriminating material. iii) Whether on the facts and circumstances of the case

Shree Mangalam Aluminium, Patna vs. Dc/ACIT, Central Circle-3, Patna

In the result, all the appeals filed by the assessee are allowed

ITA 488/PAT/2022[2016-17]Status: DisposedITAT Patna29 Jul 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 106Section 132Section 132(1)Section 133ASection 142(1)Section 143(3)Section 153ASection 153CSection 271(1)(c)

therefore, the ld. CIT(Appeals) has reduced it the estimation to 4%. He further submitted that no documentary evidence/material indicating any unaccounted purchase and/or unexplained investment was found or seized, therefore, the foundation of penalty is purely on estimation basis. The ld. CIT(Appeals) passed his orders merely by relying

Shree Mangalam Aluminium, Patna vs. Dc/ACIT, Central Circle-3, Patna

In the result, all the appeals filed by the assessee are allowed

ITA 487/PAT/2022[2015-16]Status: DisposedITAT Patna29 Jul 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 106Section 132Section 132(1)Section 133ASection 142(1)Section 143(3)Section 153ASection 153CSection 271(1)(c)

therefore, the ld. CIT(Appeals) has reduced it the estimation to 4%. He further submitted that no documentary evidence/material indicating any unaccounted purchase and/or unexplained investment was found or seized, therefore, the foundation of penalty is purely on estimation basis. The ld. CIT(Appeals) passed his orders merely by relying

Shree Mangalam Aluminium, Patna vs. Dc/ACIT, Central Circle-3, Patna

In the result, all the appeals filed by the assessee are allowed

ITA 486/PAT/2022[2014-15]Status: DisposedITAT Patna29 Jul 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. Nos. 486 To 488/Pat/2022 Assessment Year: 2014-2015 To 2016-2017 Shree Mangalam Aluminium,…...….………Appellant Pandey Plaza Building, Exhibition Road, Patna-800001, Bihar [Pan:Abkfs3963M] -Vs.- Deputy/Assistant Commissioner Of Income Tax,……………………………………………………..Respondent Central Circle-3, Patna, Bihar

Section 106Section 132Section 132(1)Section 133ASection 142(1)Section 143(3)Section 153ASection 153CSection 271(1)(c)

therefore, the ld. CIT(Appeals) has reduced it the estimation to 4%. He further submitted that no documentary evidence/material indicating any unaccounted purchase and/or unexplained investment was found or seized, therefore, the foundation of penalty is purely on estimation basis. The ld. CIT(Appeals) passed his orders merely by relying

Shailesh Goyal, Tonk vs. ACIT, Centre Circle Jaipur, Jaipur

In the result, appeal of the assessee is allowed in above terms

ITA 496/JPR/2024[2016-17]Status: DisposedITAT Jaipur29 Jul 2025AY 2016-17

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Respondent byFor Respondent: Date of hearing
Section 132(1)Section 133ASection 143(3)Section 250Section 271(1)(c)Section 69C

after making addition of Rs.1 Cr. surrendered during the survey, Rs.26,34,939/- as per para 12 of the order and Rs.1.5 Lacs as unexplained investment as per para 6 of the order. The assessee being aggrieved with the same preferred an appeal before

Madanlal Girdharilal Bugaliya, Ahmedabad vs. ITO Ward 1(2)(3), Ahmedabad

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

ITA 2024/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2010-11

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri B. P. Makwana, Sr. DRFor Respondent: Shri B. P. Makwana, Sr. DR
Section 143(1)Section 148Section 271(1)(c)Section 69

quashed. 2. That the learned National Faceless Appeal Centre, Delhi has erred in law and facts by confirming the addition of impugned unexplained investment of Rs. 25,00,000/- and therefore the learned AO should be directed to delete the said addition while computing the total income. 3. That your ... nature of the transaction. Despite being given an opportunity, the assessee failed to provide any supporting evidence. Therefore, the said amount was treated as unexplained investment under section 69 of the Act and added to the assessee’s income. Penalty proceedings under section 271(1)(c) were also initiated

Madanlal Girdharilal Bugaliya, Ahmedabad vs. ITO, Ward-1(2)(3), Ahmedabad

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

ITA 2023/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2010-11

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri B. P. Makwana, Sr. DRFor Respondent: Shri B. P. Makwana, Sr. DR
Section 143(1)Section 148Section 271(1)(c)Section 69

quashed. 2. That the learned National Faceless Appeal Centre, Delhi has erred in law and facts by confirming the addition of impugned unexplained investment of Rs. 25,00,000/- and therefore the learned AO should be directed to delete the said addition while computing the total income. 3. That your ... nature of the transaction. Despite being given an opportunity, the assessee failed to provide any supporting evidence. Therefore, the said amount was treated as unexplained investment under section 69 of the Act and added to the assessee’s income. Penalty proceedings under section 271(1)(c) were also initiated

Shivratan Motilal Rathi HUF, Pune vs. ITO, Jalna

In the result, the appeal filed by the assessee in ITA

ITA 606/PUN/2025[2011-12]Status: DisposedITAT Pune29 Jul 2025AY 2011-12

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

above ground, the Learned CIT(A) has erred in maintaining the addition made by the Ld.AO of Rs. 41,19,440/- on account of unexplained Investment provisions of Section 147 of the Act. Ground 5. The appellant craves leave to add, alter, vary, omit, amend, or delete the above grounds ... aforesaid construction activities of the assessee was found undisclosed in the return of income, therefore in order to determine unexplained investment into the cost of construction a reference under section 142A of the IT Act was made to the Departmental Valuation Officer, Nagpur. The DVO evaluated cost of construction

Shivratan Motilalji Rathi HUF, Pune vs. ITO, Jalna

In the result, the appeal filed by the assessee in ITA

ITA 605/PUN/2025[2008-2009]Status: DisposedITAT Pune29 Jul 2025AY 2008-2009

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.605 & 606/Pun/2025 िनधा"रण वष" / Assessment Years : 2008-09 & 2011-12 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By Shri Akhilesh Srivastva : Date Of Hearing 24.07.2025 : Date Of Pronouncement : 29.07.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2011-12 Respectively. 2. There Is Delay Of 64 Days In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Affidavit For Condonation That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeals Within The Prescribed Time Limit. Ld. Dr Has Not Raised Any Serious Objection To Condone The Delay, Therefore We Condone The Delay Of 64 Days & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.605/Pun/2025 For Assessment Year 2008-09 As The Lead Case For Adjudication.

For Appellant: Miss Smruti Sabnis
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 271(1)(c)Section 69

above ground, the Learned CIT(A) has erred in maintaining the addition made by the Ld.AO of Rs. 41,19,440/- on account of unexplained Investment provisions of Section 147 of the Act. Ground 5. The appellant craves leave to add, alter, vary, omit, amend, or delete the above grounds ... aforesaid construction activities of the assessee was found undisclosed in the return of income, therefore in order to determine unexplained investment into the cost of construction a reference under section 142A of the IT Act was made to the Departmental Valuation Officer, Nagpur. The DVO evaluated cost of construction

Shivratan Motilalji Rathi HUF, Pune vs. ITO, Jalna

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

ITA 604/PUN/2025[2007-08]Status: DisposedITAT Pune29 Jul 2025AY 2007-08

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.604/Pun/2025 िनधा"रण वष" / Assessment Year : 2007-08 Shivratan Motilalji Rathi Vs. Ito, Ward-1, Jalna. Huf, Rathi Rathi & Co., 501-504, Akshay Landmarks, Opp. Pu La Garden, Sinhagad Road, Jalna- 411030. Pan : Aaehr5318G Appellant Respondent Assessee By : Miss Smruti Sabnis Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 24.07.2025 Date Of Pronouncement 29.07.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.10.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2007-08. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “Ground 1. The Appellant Requests Your Honor To Condone The Delay Of 64 Days In Filing The Appeal As The Delay Was Due To Unforeseen Circumstances Beyond The Control Of The Appellant.

For Appellant: Miss Smruti SabnisFor Respondent: Shri Akhilesh Srivastva
Section 142(1)Section 142ASection 144Section 147Section 148Section 151Section 249(4)Section 249(4)(b)Section 271(1)(c)Section 69

appellant. 2 Ground 2. Learned CIT(A) has erred in maintaining the addition made by Ld. AO of Rs.5,83,870/- on account of unexplained Investment under section 69 of the Income tax Act, 1961. Ground 3. Without prejudice to above ground, the Learned CIT(A) has erred in maintaining ... addition made by the Ld.AO of Rs. 5,83,870/- on account of unexplained Investment under section 69 of the Income Tax Act, 1961 without appreciating the fact that the reopening of the assessment of the assessee is solely based on the valuation report of DVO without satisfying provisions

Jayashri Mahavir Lokhande, Panvel vs. ITO Ward 1, Panvel

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

ITA 1586/PUN/2025[2013-14]Status: DisposedITAT Pune29 Jul 2025AY 2013-14

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1586/Pun/2025 िनधा"रण वष" / Assessment Year: 2013-14 Jayashri Mahavir Lokhande, V The Income Tax Officer, Room No.01 6/A, Building S Ward-1, Panvel. No.6, Khandeshwar Apartment As Sector 1, Navi Mumbai, Khanda Colony, Panvel – 410206. Maharashtra. Pan: Acwpl8291N Appellant/ Assessee Respondent / Revenue Assessee By Shri Sarang Gudhate – Ar Revenue By Shri Sandeep P Sathe –Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 29/07/2025

Section 147Section 148Section 250Section 69

circumstances of the case and in law, Ld. Assessing Officer has erred in treating investment in property amounting to Rs. 34,15,000/- as Unexplained Investment u/s 69 r.w.s 115BBE of the Income Tax Act, 1961. 2. Under the facts and circumstances of the case and in law, reopening

Sikha Agrawal, Raigarh vs. Income Tax Officer, Ward-1, Raigarh

In the result, appeal of the assessee is partly allowed

ITA 235/RPR/2025[2019-20]Status: DisposedITAT Raipur28 Jul 2025AY 2019-20

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.235/Rpr/2025 "नधा"रण वष" /Assessment Year : 2019-20 Shikha Agrawal A-9, Ashirbadpuram Colony, Near Dhimrapur Chowk, Raigarh (C.G.)-496 554 Pan: Cjwpa0265J .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1, Raigarh (C.G) ……""यथ" / Respondent

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 115BSection 271ASection 56(2)(x)Section 69Section 69A

facts and circumstances of the case and in law, CIT(A) has erred in sustaining addition of Rs.1,98,000 on unexplained investment u/s.69, i.e., cash paid for purchase of land; addition is unjustified & is liable to be deleted." Gr.No.3 "On the facts and circumstances of the case ... consequential and Ground of appeal 3. No.5 is general. 4. Ground of appeal No.2 pertains to the addition of Rs.1,98,000/- on unexplained investment u/s.69 of the Income Tax Act, 1961 (for short ‘the Act’) i.e. cash paid for purchase of land. The relevant discussion in the assessment order

Shobhna Doshi, London vs. The Ac/Dc (Int. Txn.), Rajkot.

ITA 135/RJT/2025[2018-19]Status: DisposedITAT Rajkot28 Jul 2025AY 2018-19

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No.135/Rjt/2025 "नधा"रण वष" / Assessment Year: (2018-19) (Hybrid Hearing) Shobhana Doshi The Ac/Dc Int. Txn. Rajkot. 68 Prices Avenue Kingsbury, Room No.312, Income Tax Vs. London-Nw99Jd, United Office, Amruta Estate Kingdom-999999 Building, Near Girnar Cinema, M.G. Road, Rajkot. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bespd0115G (Appellant) (Respondent)

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT. (DR)
Section 115BSection 143Section 144CSection 144C(5)Section 147Section 148Section 69A

Mumbai erred in upholding and in directing the assessing officer in making addition of Rs. 25,00,000/-, as unexplained investment u/s 69A of the Act, by failing to appreciate that source of fixed deposit of said amount was duly explained by the Appellant and thereby levying tax at rates

Pritiben Hiteshbhai Patel, Surat vs. Income Tax Officer, Ward-3(1)(5), Surat

ITA 1247/SRT/2024[2015-16]Status: DisposedITAT Surat28 Jul 2025AY 2015-16
Section 143(3)Section 56(2)(vii)

account of investment in immovable property addressed at Block No. 127 and Block No. 128, Village Chalthan, Tal Palsana, Dist. Surat treated as alleged unexplained Investment 2. On the facts and in the circumstances of the case as well as the law on the subject, the learned Commissioner

Amit Goyal, Jaipur vs. Income Tax Office, Ward 5(2), Jaipur

In the result, the grounds raised by the assessee are dismissed and orders of the authorities below are confirmed

ITA 1312/JPR/2024[2011-12]Status: DisposedITAT Jaipur28 Jul 2025AY 2011-12

Bench: Shri Gagan Goyal & Shri Narinder Kumaramit Goyal, E-52, Lal Bahadur Nagar, Jln Marg, Jaipur 302017 Pan No. Aljpg 3338F ...... Appellant Vs.

For Appellant: NoneFor Respondent: Shri Gautam Singh Choudhary, JCIT, Ld. DR
Section 139Section 143(3)Section 147Section 148Section 234ASection 250

erred in confirming the addition made by the Ld. AO by treating Rs 10,55,000/- as unexplained investment made in the purchase of plot. The addition so made and confirmed by the Ld. CIT(A) is totally contrary to the provisions of law and facts on the record ... case of the assessee was assessed after making addition of Rs. 1,65,490/- under the head salary and unexplained investment of Rs. 10.55 Lacs in house property. The assessee being aggrieved with the same, preferred an appeal before the Ld. Addl./JCIT (A)- 2, Mumbai, who in turn confirmed