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Issues: Whether the alleged unexplained investment attributable to the assessee in jointly owned property was required to be apportioned according to his documented contribution rather than equally among the co-owners.
Analysis: The registered sale deed, bank statements and payment details established the actual contributions of the three co-owners towards the recorded purchase consideration. The assessee's documented contribution represented 17% of that consideration. In the absence of evidence that the alleged cash payment was made equally by all co-owners or that the assessee contributed beyond his recorded share, allocation of one-third merely on the basis of joint registration was arbitrary. Any otherwise sustainable addition relating to the property investment was therefore required to follow the actual contribution ratio.
Conclusion: The addition attributable to the assessee was restricted to 17% of Rs.26,57,000/-, namely Rs.4,51,690/-, instead of Rs.8,85,667/-.