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Unexplained investment in land purchase - society's purchase in its name or trustees' names - CIT(A) considered money not paid by society from income but sourced from office bearers - AO held amount in sale deed is society's unexplained investment, not office bearers' undisclosed income. IBS noted society had no income for land purchase and no society reference in seized material. IBS accepted trustees' additional income utilized for society's land investment, trustees found with unaccounted money, not society. CIT(A) erred in observing no evidence of money flow from trustees when mobile data showed trustees' unaccounted money. Source investment can't be taxed again in society's hands after being taxed in trustees' hands. Non-submission of statements not controverted by department. No evidence of cash flow spent elsewhere, onus on AO to prove. Based on seized documents, trustees' unaccounted money paid for society's land can't be added to society's income. Ground allowed.
Unexplained investment in land purchase - society's purchase in its name or trustees' names - CIT(A) considered money not paid by society from income but sourced from office bearers - AO held amount in sale deed is society's unexplained investment, not office bearers' undisclosed income. IBS noted society had no income for land purchase and no society reference in seized material. IBS accepted trustees' additional income utilized for society's land investment, trustees found with unaccounted money, not society. CIT(A) erred in observing no evidence of money flow from trustees when mobile data showed trustees' unaccounted money. Source investment can't be taxed again in society's hands after being taxed in trustees' hands. Non-submission of statements not controverted by department. No evidence of cash flow spent elsewhere, onus on AO to prove. Based on seized documents, trustees' unaccounted money paid for society's land can't be added to society's income. Ground allowed.
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