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Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
Section 69 requires material showing that the assessee itself made an investment not recorded in its books. Payments allegedly made towards land before the assessee firm was constituted could not be treated as its unexplained investment where the predecessor entity accepted responsibility and the assessee recorded the corresponding liability on taking over the project. General partner statements could not displace contemporaneous dates, books, and banking records without supporting enquiry or corroborative evidence. Questions concerning the predecessor's source of funds required examination in that entity's assessment. The unexplained-investment addition, consequential tax, and interest were deleted.
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