Unexplained investment claims need admissible proof; a new HUF source raised at Tribunal was not accepted.

Investments treated as unexplained were not deleted on the basis of a new HUF source explanation raised for the first time before the Tribunal. The assessee had not advanced that claim before the assessing authority or the first appellate authority, and the documents filed at the Tribunal were additional evidence without any Rule 29 application. A bank statement showing withdrawals, without supporting accounts or balance sheets for the relevant years, was held insufficient to prove that the HUF had funds available at the time of investment. The additions were therefore sustained.

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Issues: Whether the additions made by treating the investments as unexplained were liable to be deleted on the basis of a new claim that the investments were sourced from the assessee's HUF and on the basis of documents produced for the first time before the Tribunal.

Analysis: The assessee did not advance the HUF source explanation before the assessing authority or the first appellate authority. The documents produced before the Tribunal were additional evidence, no application for their admission was made under Rule 29, and the material was not sufficient to establish availability of funds with the HUF at the relevant time. A bank statement showing withdrawals, without supporting accounts or balance sheet for the relevant years, was held inadequate to explain the individual investments treated as unexplained.

Conclusion: The new explanation was not entertained and the additions sustained by the lower authorities were upheld.

Ratio Decidendi: A new source of investment raised for the first time at the Tribunal cannot be accepted as a matter of course, especially when unsupported by admissible and reliable evidence showing availability of funds at the relevant time.

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