https://www.taxtmi.com/caselaws?id=787361 Section 69 permits a substantive addition for an investment standing in an individual's name where the individual does not satisfactorily establish its source. Although an HUF is a separate taxable entity, a claim that the investment belonged to the HUF requires cogent contemporaneous evidence, including books, sale records, cash-flow material or transaction documents. The absence of such evidence, coupled with transactions preceding the asserted arrangement, supports treating the investment as unexplained in the individual's hands. Protective assessment applies only where the Assessing Officer has genuine doubt about the person chargeable; it cannot be invoked to recast a concluded substantive addition as protective. en-us Wed, 25 Feb 2026 00:00:00 +0530 Tue, 03 Mar 2026 08:42:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787361 Section 69 permits a substantive addition for an investment standing in an individual's name where the individual does not satisfactorily establish its source. Although an HUF is a separate taxable entity, a claim that the investment belonged to the HUF requires cogent contemporaneous evidence, including books, sale records, cash-flow material or transaction documents. The absence of such evidence, coupled with transactions preceding the asserted arrangement, supports treating the investment as unexplained in the individual's hands. Protective assessment applies only where the Assessing Officer has genuine doubt about the person chargeable; it cannot be invoked to recast a concluded substantive addition as protective. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787361