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“investment not fully disclosed”

Cash Credits & Unexplained ItemsSection 69BSection 69B13 judgments

The decision most relied on for investment not fully disclosed is Commissioner of Income-tax v. Cholamandalam Investment and Finance Co. Ltd. (309 ITR 110), cited in 17 judgments on BharatTax.

Leading authorities on investment not fully disclosed

Commissioner of Income-tax v. Cholamandalam Investment and Finance Co. Ltd.
309 ITR 110 · 2009 · High Court
17
citing judgments

An assessee has not failed to disclose fully and truly all material facts relevant for assessment when the Assessing Officer had called for and received all details regarding claims, such as 100% depreciation, along with supporting invoices. A claim being unsustainable in law does not automatically amount to furnishing inaccurate particulars for penalty purposes.

Judgments citing investment not fully disclosed

Assistant Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Harbans Singh Sadhiora Prop. M/S Neeta Jewellers, Gill Road, Janta Nagar, Ludhiana

In the result, appeal filed by the Revenue is dismissed

ITA 1110/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh09 Mar 2026AY 2019-20

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 115BSection 69B

during assessment proceedings which was duly assessed under the provision of section 69B r.w.s 115BBE of the Act being the unexplained investment not fully disclosed in the books or account? The appellant craves leave to add, amend, modify, vary, omit OR substitute any 3. of the aforesaid grounds of appeal

Ssgr Hospital and Research Centre Private Limited, Haldwani vs. DCIT/ACIT, Central Circle, Haldwani

In the result, appeals of the Assessee in ITA Nos

ITA 73/DDN/2025[2014-2015]Status: DisposedITAT Dehradun17 Sept 2025AY 2014-2015

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 142(1)Section 153ASection 69B

Valuation as per the Report and the value shown by the assessee company for the year under consideration was treated as unexplained investment not fully disclosed in books of accounts accordingly, made addition u/s 69B of the Act in all the years under consideration vide assessment orders dated 28/12/2019 pertaining

Ssgr Hospital and Research Centre Private Limited, Haldwani vs. DCIT/ACIT, Central Circle, Haldwani

In the result, appeals of the Assessee in ITA Nos

ITA 72/DDN/2025[2013-2014]Status: DisposedITAT Dehradun17 Sept 2025AY 2013-2014

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 142(1)Section 153ASection 69B

Valuation as per the Report and the value shown by the assessee company for the year under consideration was treated as unexplained investment not fully disclosed in books of accounts accordingly, made addition u/s 69B of the Act in all the years under consideration vide assessment orders dated 28/12/2019 pertaining

Ssgr Hospital and Research Centre Private Limited, Haldwani vs. DCIT/ACIT, Central Circle, Haldwani

In the result, appeals of the Assessee in ITA Nos

ITA 71/DDN/2025[2012-2013]Status: DisposedITAT Dehradun17 Sept 2025AY 2012-2013

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 142(1)Section 153ASection 69B

Valuation as per the Report and the value shown by the assessee company for the year under consideration was treated as unexplained investment not fully disclosed in books of accounts accordingly, made addition u/s 69B of the Act in all the years under consideration vide assessment orders dated 28/12/2019 pertaining

Ssgr Hospital and Research Centre Private Limited, Haldwani vs. DCIT/ACIT, Cental Circle, Haldwani

In the result, appeals of the Assessee in ITA Nos

ITA 70/DDN/2025[2011-2012]Status: DisposedITAT Dehradun17 Sept 2025AY 2011-2012

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 142(1)Section 153ASection 69B

Valuation as per the Report and the value shown by the assessee company for the year under consideration was treated as unexplained investment not fully disclosed in books of accounts accordingly, made addition u/s 69B of the Act in all the years under consideration vide assessment orders dated 28/12/2019 pertaining

Ssgr Hospital & Research Centre Private Limited, Haldwani vs. Dc/ACIT, Central Cirlce, Haldwani

In the result, appeals of the Assessee in ITA Nos

ITA 41/DDN/2025[2015-2016]Status: DisposedITAT Dehradun17 Sept 2025AY 2015-2016

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 132Section 142(1)Section 153ASection 69B

Valuation as per the Report and the value shown by the assessee company for the year under consideration was treated as unexplained investment not fully disclosed in books of accounts accordingly, made addition u/s 69B of the Act in all the years under consideration vide assessment orders dated 28/12/2019 pertaining

Sh. Dilip Kumar, Kota vs. DCIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 208/JPR/2025[2018-19]Status: DisposedITAT Jaipur26 May 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 115BSection 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 250Section 68Section 69

disclosed. It is further submitted that AO has considered the income of Rs.40,02,994/- offered for tax as unexplained investment/unexplained money/amount of investment not fully disclosed in the books of accounts as per the provisions of section 69 and 69A of the Act. These sections applies where assessee

Rajiv Kumar Goyal, Dhuri vs. DCIT, CC-2, Ludhiana

In the result, the appeal of the assessee is allowed

ITA 79/CHANDI/2023[2019-20]Status: DisposedITAT Chandigarh22 May 2024AY 2019-20

Bench: This Hon’Ble Tribunal Under Section 253 Of The Income Tax Act, 1961 As Amended From Time To Time. 2. The Assessee Is Aggrieved By Order Of The Ld. Cit(A) Dated 03/02/2023 In Appeal No. 10850/2018-19/It/Cit(A)-5/Ldh/2021-22 For A.Y. 2019-20 Under Section 250(6) Of The Income Tax Act, 1961 Which Was Dismissed. Therefore The Present Second Appeal Under Section 253 Of The Income Tax Act, 1961 Before Us Against The Aforesaid Order Dt. 03/02/2023 Which Is Hereiafter Referred To As The Impugned Order. Factual Matrix 3. The Assessee Had For The Relevant Year I.E; A.Y. 2019-20 Was Also Engaged In The Same Business I.E; Manufacturing Of Pvc Pipes & Had Filed

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Rishaba Marwaha, C.AFor Respondent: Shri Dharamvir, JCIT, Sr. D.R
Section 133ASection 139(1)Section 250(6)Section 253

excess stock found during the course of survey is not considered to be business income of the assessee but considered as unexplained investment not fully disclosed in the books of the accounts of the assessee u/s 69B of the Income Tax Act, and charged to tax as per the provisions

Jitesh Jitendra Sakhidas, Mumbai vs. ITO Ward 30 (1) (5), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3112/MUM/2023[2012-13]Status: DisposedITAT Mumbai27 Feb 2024AY 2012-13

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nitesh Joshi, CAFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 131Section 133ASection 143(1)Section 69B

paid by the assessee to M/s Rashmi Infrastructure Developers Ltd. for the purchase of flat No. 1006 in their project constitutes unexplained investment not fully disclosed in his books of account. Accordingly, the said amount is taxed u/s 69B of the Act and added to the total income

DCIT, Central Circle-2(1), Chennai vs. M/S Hill Max Export, Coimbatore

In the result, appeal filed by the revenue is dismissed

ITA 742/CHNY/2023[2016-17]Status: DisposedITAT Chennai24 Jan 2024AY 2016-17

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपीलसं./Ita No.: 742/Chny/2023 & Co No.: 39/Chny/2023 िनधा"रणवष" / Assessment Year: 2016-17 Deputy Commissioner Of Income M/S. Hill Max Export, Tax, V. No. 149/1, Central Circle 2(1), Pollachi Main Road, Room No. B3, Ground Floor, Kattampatti, Investigation Building, Jakkarpalayam-Vaipollachi, Chennai – 34. Coimbatore – 642 202. [Pan:Aahfh-2574-B] (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ"क"ओरसे/Appellant By : Shri. V. Nanda Kumar, Cit Respondent/Cross Objector By : Shri. M. V. Prasad, Fca सुनवाई क" तारीख/Date Of Hearing : 28.12.2023 घोषणा क" तारीख/Date Of Pronouncement : 24.01.2024

For Appellant: Shri. V. Nanda Kumar, CIT
Section 132Section 133ASection 139Section 142(1)Section 153CSection 69B

sustainability of the addition made in the assessment order on merits is adjudicated in the following paragraphs. ADDITION U/S 69B TOW ARDS INVESTMENT NOT FULLY DISCLOSED IN BOOKS OF ACCOUNT :-12-: ITA. No: 742/Chny/2023 & CO No: 39/Chny/2023 20. In Ground No.11 of appeal, the appellant has disputed the addition ... Rs.5,34,00,000/- made u/s 69B towards the investment not fully disclosed in the books of account represented by the on-money payment made to M/s Gulyam Cot Spin in pursuance of the agreement of sale dated 01.04.2015. 21. The AO made the said addition having regard

The DCIT Central-3, Indore vs. M/S Hanuman Proessor, Burhanpur

ITA 169/IND/2023[2020-21]Status: DisposedITAT Indore30 Nov 2023AY 2020-21

Bench: Shri Vijay Pal Rao & Shrib.M. Biyaniassessment Year: 2020-21 Dy. Cit, M/S.Hanuman Processors, Central-3, Alamganj, बनाम/ Indore. Burhanpur Vs. (Revenue / Appellant) (Assessee / Respondent) Pan: Aaafh7777 F

Section 115BSection 133ASection 143(2)Section 143(3)Section 69B

grounds of appeal, the appellant has challenged the addition made by the Ld. AO amounting to Rs. 1,27,25,000/- on account investment not fully disclosed in books of account u/s 69B of the Act and charging of tax as per amended provisions of section 115BBE

Deputy Commissioner of Income Tax, Central Circle, Jabalpur vs. M/S. Vijan Hotel Pvt. Ltd., Jabalpur

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

ITA 38/JAB/2020[2017-18]Status: DisposedITAT Jabalpur20 Oct 2023AY 2017-18

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadaleita No. 37 & 38/Jab/2020 (A.Y: 2016-17 & 2017-18) Dcit, Central Circle, Vs. Vijan Hotel Pvt Ltd, 291, Ramnath Bldg, Khasra No114/2 & Napier Town, Part Of 107, Jablapur-482001, Mandla Road, Tilhari Madhyapradesh. Jabalpur-482001. Madhyapradesh. Pan/Gir No. : Abzpn0126C Appellant .. Respondent C.O No.02 & 03/Jab/2021 (A.Y: 2016-17 & 2017-18) Vijan Hotel Pvt Ltd, Vs. Dcit, Central Circle, Khasra No114/2 & 291, Ramnath Bldg, Part Of 107, Napier Town, Mandla Road, Tilhari Jablapur-482001, Jabalpur-482001. Madhyapradesh. Madhyapradesh Pan/Gir No. : Abzpn0126C Appellant .. Respondent Appellant/Respondentby Shri, Saad Kidwai. Cit Dr Respondent/Appellantby Shri.Dhiraj Ghai. Fca. Ar Date Of Hearing 21.09.2023 Date Of Pronouncement 16.10.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm:

Section 131(1)Section 142(3)Section 147Section 148

view of the above, considering the facts and the circumstances, difference of cost i.e. Rs. 3,37,92,626/- is treated as investment not fully disclosed u/s 69B of the Income Tax Act in the books of account of the assessee and therefore added back to the total income

DCIT (Ex) - 1(1), Mumbai vs. The Lohar Chawl Dawoodi Bohra Merchants Association, Mumbai

In the result, appeal filed by the learned Assessing Officer is dismissed

ITA 3635/MUM/2018[2012-13]Status: DisposedITAT Mumbai19 Jan 2022AY 2012-13

Bench: Ms Suchitra Kamble & Shri Prashant Maharishithe Dy. Commissioner Of The Lohar Chawl Dawoodi Income Tax (Ex) -1(1) Bohra Merchants’ Association Room No. 506, 5 Th Floor, Piramal Chambers, 56/62, Chandabai Bldg., Vs. Lalbaug, Parel, 2Nd Floor, Mangaldas Road, Lohar Chawl, Mumbai-400 012 Mumbai-400 002 Pan No. Aaatl0024D Appellant .. Respondent

For Appellant: Shri Deepak TralshawalaFor Respondent: Ms. Surabhi Sharma, CIT DR
Section 1Section 11Section 13(3)Section 36ASection 36A(3)Section 69A

treated four undisclosed bank accounts deposits as covered under the provisions of Section 69A and 69B as unexplained money and amount of investment not fully disclosed in the accounts of the assessee as per provisions of the law. iv. He also considered the explanation of the assessee of mutual concern