Unexplained investment sustained where source was not proved and factual findings did not raise a substantial question of law.

An addition for unexplained investment under Section 69 was sustained because the assessee failed to produce the agreement, did not present the vendor for examination, and the third party statement under Section 131 supported payment for the land transaction. On those surrounding circumstances and documentary material, the authorities found that the source of the investment was not satisfactorily explained, and that finding was treated as factual. No substantial question of law arose under Section 260-A, so interference was not warranted.

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Issues: Whether the addition of Rs. 20,00,000 as unexplained investment under Section 69 of the Income Tax Act, 1961 was justified, and whether any substantial question of law arose in the appeal.

Analysis: The assessee failed to produce the relevant agreement and also did not produce the vendor for examination, while the statement of the third party recorded under Section 131 of the Income Tax Act, 1961 supported the existence of payment towards the land transaction. The authorities relied on the surrounding circumstances and the documentary material to hold that the explanation regarding source of the investment was not satisfactorily established. The Court also held that the finding was one of fact and no substantial question of law arose for interference under Section 260-A of the Income Tax Act, 1961.

Conclusion: The addition of Rs. 20,00,000 as unexplained investment was upheld and the appeal failed.

Ratio Decidendi: Where the assessee does not satisfactorily explain the source of investment and the factual finding is supported by evidence and surrounding circumstances, interference under Section 260-A of the Income Tax Act, 1961 is not warranted.

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