Unexplained investment addition fails when documentary evidence shows the property payment related to an earlier year.

Addition for unexplained investment under section 69 read with section 115BBE is stated to be unsustainable where the assessee produces registered purchase documents, bank records and a plausible explanation showing that the property consideration was paid in an earlier financial year. The note records that the Assessing Officer did not rebut this evidence with cogent material or independent verification, so the assessee's initial onus was treated as discharged and the burden shifted to the Revenue, which was not met. The addition was deleted on merits, while the reassessment challenge was left open and not decided.

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Issues: Whether the addition made as unexplained investment under section 69 read with section 115BBE of the Income-tax Act, 1961 could be sustained when the assessee produced registered purchase documents, bank evidence and explanation showing that the impugned property transaction pertained to an earlier year.

Analysis: The assessee furnished documentary material, including the purchase agreement and bank records, to show that the consideration was paid in financial year 2014-15 and not in the year under consideration. The Assessing Officer rejected the explanation without bringing any material to disprove the assessee's claim or to independently verify that the investment was made in the relevant previous year. The appellate record also showed that the explanation was not effectively rebutted by cogent evidence. In these circumstances, the initial onus stood discharged by the assessee and the burden shifted to the Revenue, which was not met.

Conclusion: The addition under section 69 read with section 115BBE was not sustainable and was deleted, in favour of the assessee.

Final Conclusion: The assessment addition was set aside on merits, while the challenge to the reassessment proceedings was left open and not adjudicated.

Ratio Decidendi: An addition for unexplained investment cannot be sustained merely on unverified information or suspicion once the assessee produces credible documentary evidence indicating that the transaction pertains to an earlier year; the Revenue must then establish the alleged investment in the relevant year by cogent material.

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