9911796707
TMI Blog2025 (3) TMI 654X X X X Extracts X X X X X X X X Extracts X X X X ..... n brief are that the assessee field the return of income on 28th August, 2015, declaring total income of Rs. 3,41,700/-, after claiming deduction under Chapter VIA of Rs. 1,11,708/-. Thereafter the AO received information from Bureau of Investigation, Commercial Tax, West Bengal that Shri Rajesh Kumar Jalan has received the payments to the tune of Rs. 112,41,47,898/- through seven bank accounts in the name of 6 traders during the period commencing from 2012-13 to 2015-16. The ld. AO also noted that assessee has purchased one immovable property for a consideration of Rs. 41,21,145/- which registered before Registrar of Assurances on 04.07.2014. According to the ld. AO, the assessee has not responded to the notice issued on 06.09.2021, callin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Rs. 41,21,145/-, the factual matrix is as follows:- That assessee purchased a disputed and disturb property (uncleared title) at Rs. 15,00,000/-(Rupees Fifteen Lakhs) but the same was valued by registrar at Rs. 41,21,145/- in a casual manner. Assessee paid the consideration amount by cheque during the year and paid the Stamp Duty and Registration Fees on Rs. 41,21,145/-. Hence, NO circumstances the same is unexplained investment, A.O notice u/s 142(1) should be specific and transparent manner. Section 115BBE not attracted in this case. Additions in this regard is bad in law." 9.2 However, this reply is not acceptable as the appellant failed to substantiate the source of investment with supporting documents. Hence the addition made by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ents and it is stated in the section that in the financial year immediately preceding assessment year, if the assessee has made investments which are not recorded in the books of account, if any, maintained by the assessee for any source of income and the assessee offers no explanation about the nature and source of investments or explanation offered by him is not in the opinion of the ld. AO satisfactory, then value of investments may be deemed to be income of the assessee of such financial year. However, in the present case, it is undisputed that the payments were made from the bank accounts of the assessee which were before the ld. AO and even the ld. AO has extracted the details of the bank accounts at page no.5 and 6 of the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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