Unexplained investment claims fail when source of funds is fully corroborated and the Revenue offers no contrary evidence.

An addition for unexplained investment under section 69 was treated as unsustainable where the assessee produced a complete documentary trail for the property purchase, including the earlier sale deed, bank records, affidavit, gift deed, identity and tax documents, bank confirmation and pay order. The analysis states that the Revenue did not dispute the genuineness of the transaction, the contributor's identity or capacity, or the receipt of funds by the seller, and offered no contrary material showing undisclosed income. On that basis, the text says the investment stood satisfactorily explained and the addition was deleted; the absence of one collateral remittance record was not enough to reject otherwise corroborated evidence.

---

---

Issues: Whether the addition made under section 69 of the Income-tax Act, 1961 towards alleged unexplained investment in purchase of immovable property, including the small balance amount, was sustainable when the assessee produced documentary evidence explaining the source and movement of funds.

Analysis: The assessee furnished a source-wise reconciliation of the entire purchase consideration, supported by the sale deed of the earlier property, the seller's bank statement, the husband's affidavit, the gift deed, identity and tax records of the husband, the bank confirmation identifying the remitter, and the pay order for the balance amount. The Revenue did not dispute the genuineness of the purchase transaction, the identity and capacity of the contributor, or the receipt of funds by the seller, and brought no contrary material to show that the money represented undisclosed income of the assessee. The mere non-availability of an exchange bureau remittance record, by itself, was held insufficient to reject the explanation when the transaction stood otherwise fully corroborated.

Conclusion: The assessee had satisfactorily explained the entire investment, and the addition under section 69 was not sustainable; the impugned addition of Rs. 80,10,000/- was directed to be deleted.

Ratio Decidendi: Where the assessee establishes the source of investment through a coherent chain of corroborative evidence and the Revenue brings no rebuttal material, an addition for unexplained investment under section 69 cannot rest on suspicion or on the absence of one collateral document.

---