Unexplained investment addition deleted where documentary evidence and remand verification established earlier-year property purchases.

Addition under section 69 for alleged unexplained investment in immovable property was deleted where the assessee produced registered agreements, bank statements, receipts and audited balance sheets showing that the investments were made in earlier years and were recorded in the books. The original addition rested mainly on AIR information and non-compliance during assessment, but remand verification confirmed that the flats were purchased earlier and that the shop investment was also supported by records, with the higher AIR value reflecting registration-time valuation. On those findings, the source and timing of the investments were satisfactorily explained, and the revenue's challenge failed.

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Issues: Whether the addition made under section 69 on account of alleged unexplained investment in immovable properties was sustainable when the assessee produced registered agreements, bank statements, receipts and audited balance sheets showing that the investments were made in earlier years and stood recorded in the books.

Analysis: The addition was made only on the basis of AIR information and the assessee's non-compliance during assessment proceedings. In remand proceedings, the Assessing Officer verified the documents and accepted that the residential flats were purchased in an earlier year and reflected in the balance sheet, and that the shop investment was also supported by the records and the higher AIR value represented the registration-time valuation. The materials established that the source and timing of the investments were duly explained and that no investment was made in the year under appeal.

Conclusion: The addition under section 69 was rightly deleted and the revenue's challenge failed.

Final Conclusion: The disputed investment additions did not survive judicial scrutiny, as the evidence on record and the remand findings established that the assessee had satisfactorily explained the property transactions.

Ratio Decidendi: Where investment in immovable property is supported by contemporaneous documentary evidence and verified in remand, an addition for unexplained investment cannot be sustained merely because the assessee did not respond during the original assessment.

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