Unexplained investment addition fails where registered sale deed and banked sources support declared property consideration.

Section 69 addition for alleged unexplained investment in immovable property was not sustainable where the registered sale deed recorded the purchase consideration, the source was explained through a joint housing loan and bank savings, and no independent material showed payment of any on-money. A valuation report obtained at the appellate stage was only an estimate and could not, by itself, rebut the declared consideration or displace the presumption of correctness attached to the registered document. The fact that the co-owner's assessment on the same transaction had accepted the declared investment also supported deletion of the addition, which was accordingly removed in favour of the assessee.

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Issues: Whether the addition made under section 69 on account of alleged unexplained investment in the purchase of immovable property could be sustained in the absence of any material showing payment over and above the registered sale consideration.

Analysis: The investment in the property stood recorded in a registered sale deed at Rs. 40 lakhs and the source was explained through joint housing loan and bank savings. No independent material was brought on record to show payment of any on-money. The valuation report obtained at the appellate stage was only an estimate and could not by itself displace the declared consideration. The assessment of the co-owner, on the same transaction, had also accepted the declared investment. In such circumstances, the registered document carried a presumption of correctness and the addition could not be sustained merely on the basis of valuation opinion.

Conclusion: The addition under section 69 was deleted and the issue was decided in favour of the assessee.

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