Unexplained investment addition deleted where inherited property sale proceeds and bank records proved the source for new property purchase.

Unexplained investment in immovable property was held not sustainable where the assessee showed that funds came from sale proceeds of an inherited property. Bank statements and related documents established that the sale consideration was credited and then used for the new property purchase jointly with family members. The documentary trail also showed that the mother's connected transactions had already been accepted in assessment, supporting the source of investment. On these facts, the addition made in set-aside proceedings was deleted.

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Issues: Whether the addition made as unexplained investment in respect of purchase of immovable property was sustainable, where the assessee claimed that the investment was sourced from sale proceeds of inherited property and supported the claim with bank statements and other documents.

Analysis: The assessee established that the old inherited property had been sold and that the sale consideration was credited in the bank account and used for purchase of the new property jointly with family members. The record also showed that the transactions in the case of the assessee's mother had already been accepted in assessment, and the documentary trail supported the availability of source for the investment. On these facts, the addition sustained in set-aside proceedings could not be upheld.

Conclusion: The addition was deleted and the issue was decided in favour of the assessee.

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