2025 (8) TMI 821

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....er of the NFAC/CIT(A) dt. 08.01.2024 for A.Y. 2017-18 as per the grounds of appeal on record. 2. In this case the assessment was completed on 30.03.2022 u/s 147 r.w.s 144 of the Act. The following additions were made:- (1) Rs. 12,00,000/- as undisclosed investment u/s 69 of the Act; (2) Rs. 27,26,800/- as income from other sources u/s 56(2) (vii b) of the Act. The relevant facts in narration....

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....d on 31.03.22 the AO proceeded to complete the assessment based on material available on record. It was observed by the AO from the bank account that the assessee had paid only Rs. 20 lakhs to Md. Sohail Akhtar on various dates. In absence of any documentary evidence therefore, the difference of [Rs. 32,00,000/- - Rs. 20,00,000/-] i.e. Rs. 12,00,000/- was added u/s 69 of the Act as undisclosed inv....

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..... 4. I have heard the rival submissions of the parties herein, have carefully considered the documents on record and have analysed the facts and circumstances in this case. The assessee has admitted to have paid the sale consideration for purchase of the that flat, to Md. Sohail Akhtar for Rs. 32,00,000/-. Along with this reply the assessee had enclosed bank account details and loan documents. Th....

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....DR could not refute these facts on record. Per Contra ld. AR vehemently challenged the validity of the additions made in this case. He submitted that the assessment was completed on a summary basis without conducting adequate enquiry regarding the facts of the case. That even the principles of natural justice had been violated since without adequate opportunity of hearing the additions were made a....