Unexplained investment in property required fresh verification where claimed sale proceeds lacked reliable proof and documentation.

Reassessment relating to unexplained investment in immovable property turned on whether the assessee had satisfactorily proved the source of funds through alleged sale proceeds of ancestral land. Repeated non-compliance, lack of verifiable documents, uncertainty over the assessee's share in the ancestral property, and absence of a registered sale deed meant the explanation required further enquiry on ownership, possession and transferability. The deletion of the addition was therefore not sustained on the existing material, and the matter was restored to the Assessing Officer for fresh verification and a fresh assessment after giving the assessee an opportunity of hearing.

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Issues: Whether the deletion of addition made on account of unexplained investment in purchase of immovable property could be sustained, or whether the matter required fresh verification by the Assessing Officer.

Analysis: The assessment arose from reassessment proceedings initiated on information regarding purchase of immovable property. The assessee claimed that the investment was explained by sale proceeds of ancestral land said to have been sold under an unregistered agreement to a purchaser from Sikkim. The record showed repeated non-compliance during assessment, absence of verifiable documentary evidence, uncertainty about the assessee's share in the alleged ancestral property, and no registered sale deed despite the passage of time. In these circumstances, the explanation of source of investment and the genuineness of the claimed transaction required further enquiry, particularly on ownership, possession, and transferability of the land.

Conclusion: The deletion of the addition was not upheld on the existing material and the matter was restored to the Assessing Officer for fresh enquiry and a fresh assessment after giving the assessee an opportunity of hearing.

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