2025 (9) TMI 577

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.... 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2018-19. 2. The assessee has raised the following grounds of appeal:- "01. That the Ld. CIT(A), NFAC has erred both in law and on facts while sustaining the addition made by Ld. A.O. of Rs. 89,400/-, and therefore it requires to be deleted. 02. That the Ld. CIT(A), NFAC has not consider the submissions made by the appellant and addition sustained u/s 69 of the I.T. Act, 1961 for Rs. 89,400/- is against the principal of natural justice and require to be deleted. 03. That the appellant has explained the source of payments of Rs. 89,400/-, however without appreciating the facts and documents on record addition sustained of Rs. 89,400/....

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....d submission of the appellant along with the remand report submitted by the AO and the endorsement of the Range Head. 6.2 Vide various grounds of appeal, the appellant has raised the sole issue of addition of Rs. 5,89,400/- as unexplained money invested in the purchase of immovable property u/s 69 of the Act. After going through the remand report, it is seen that the appellant has claimed to have received Rs. 5,00,000/- as loan from one Sh. Vaibhav Piyushbhai Brahmbhatt in the form of banking transaction. The appellant submitted copy of PAN and bank statement of the lender and after examining the same the AO has accepted the genuineness and identity of the lender. However, the AO has submitted that as the purported lender has filed....

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....o other loan transactions as source of the purchase of the immovable property I.e. a loan of Rs. 30,894/- from Atulbhai Brahmbhatt HUF (appellant's brother HUF) and Rs. 58,416/- from one Sh. Ashokbhai Brahmbhatt (appellant's brother). However, an analysis of the bank statements of these two persons revealed that both the amounts were received by the appellant after the date of purchase of property i.e. after 09.03.2018. It is also noted that as per the conveyance deed entered into on 09.03.2018, the entire consideration was paid and no payment to the seller was outstanding which could have been paid through any of the above two loans. Hence, the said contention of the appellant is rejected and addition to the extent of Rs. 89,400/- ....