Unexplained investment addition fails where SFT and Form 26AS entries are unsupported by bank details and verification.

An addition for unexplained investment could not be sustained merely on SFT and Form 26AS entries where the Revenue did not identify the relevant bank account or produce corroborative material showing the impugned credit was actually received by the assessee. The assessee denied the current account reference, furnished savings account details and a third-party confirmation explaining that the entry arose from a technical or uploading error. As the explanation and additional evidence were not independently verified, and no supporting particulars established unexplained investment, the deletion by the first appellate authority was upheld.

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Issues: Whether an addition for unexplained investment could be sustained solely on the basis of SFT and Form 26AS information without specifying the relevant bank account details and without independent verification of the assessee's reconciliation and third-party confirmation.

Analysis: The assessment was founded on information reflected in the SFT system, but the record did not contain the necessary particulars of the bank account or supporting material to show that the impugned amount was actually credited to the assessee. The assessee denied maintaining the current account referred to by the Assessing Officer and furnished details of savings bank accounts as well as a confirmation from the concerned entity explaining that the entry had been wrongly reflected due to a technical/uploading error. The additional evidence was not effectively examined and no corroborative material was brought on record to establish unexplained investment under the Act.

Conclusion: The addition was not sustainable and the deletion made by the first appellate authority was upheld.

Final Conclusion: The appeal failed and the relief granted to the assessee was maintained.

Ratio Decidendi: An addition for unexplained investment cannot rest only on SFT or Form 26AS entries unless the Revenue identifies the underlying transaction with supporting particulars and verifies the assessee's explanation and supporting confirmations.

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