Unexplained investment reversed where bank-backed contributions from deceased spouse were documented; addition deleted on appeal.

Whether an addition as unexplained investment was justified where the assessee established source as contributions from the deceased spouse through sale deed, schedule of payments, bank statements and reconciled account entries; the departmental authorities identified no alternate source and payments were routed through banking channels. The appellate authority failed to independently scrutinise the documentary trail. On these facts the addition under Section 69 was deleted and the appeal allowed in favour of the assessee.

---

---

Issues: Whether addition under Section 69 of the Income-tax Act, 1961 for unexplained investment in immovable property is justified where the assessee explains the source of funds as contributions from the deceased spouse supported by bank statements, sale deed and related documentary evidence.

Analysis: The assessment was reopened under Section 147 and an addition under Section 69 was made treating 50% of the aggregate purchase consideration as unexplained investment attributable to the assessee. On record are the sale deed showing joint ownership, a schedule of payments in the sale deed, detailed payment entries and bank statements demonstrating transfers from the husband's fixed deposits, transfers from a mutual fund and credits into the joint account; the husband had died before assessment proceedings and his tax returns and death certificate were also placed on record. The departmental authorities did not identify any alternate source of income of the assessee and the documentary trail establishes that payments were routed through banking channels and reconciled with account entries. The first appellate authority sustained the addition without independent factual scrutiny of these documents.

Conclusion: Addition under Section 69 of the Income-tax Act, 1961 deleted; appeal allowed in favour of the assessee.

---