Unexplained property investment remanded for verification of source of funds claimed to be provided by son

Unexplained investment in property could not be conclusively assessed in the assessee's hands without first verifying her claim that the funds came from her non-resident son's remittances and resources. As one property investment had already been accepted in the son's case as explained, the Tribunal found limited factual verification necessary for the remaining property. The matter was therefore restored to the Assessing Officer for restricted examination of the source of investment, and the addition was not finally sustained at this stage.

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Issues: Whether the addition made towards unexplained investment in property could be sustained in the assessee's hands without verifying the source of funds alleged to have been provided by her son, and whether the matter required restoration for limited verification.

Analysis: The assessment had been completed ex parte and the appellate authority had declined relief on limitation. On the material placed before the Tribunal, it emerged that the assessee claimed the investment was made by her non-resident son from his own remittances and resources. In relation to one property, the corresponding investment had already been accepted in the son's case as being from explained sources. The Tribunal therefore found it necessary to verify, in the assessee's case, whether the remaining property was also purchased from funds provided by the son. Since the issue turned on factual verification of the source of investment, the matter was restored to the jurisdictional Assessing Officer for limited adjudication.

Conclusion: The addition was not finally sustained at this stage and the issue was remanded for limited verification of the source of investment; the assessee obtained partial relief.

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