2025 (11) TMI 734

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....der Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2019-20. 2. The Revenue has raised the following grounds of appeal:- "Whether on the facts and in circumstances of the case, Ld. CIT is justified in deleting the addition u/s 69 of the I.T. Act, 1961 of Rs. 38,72,56,429/- being unexplained investment in time deposits." 3. The brief facts of the case are that the assessee, Gujarat University, is a statutory body established under the Gujarat University Act, 1949, and is engaged in the field of higher education, research, and extension activities. It is substantially financed by the Government, and its income is exempt under section 10(23C)(iiiab) of the Act. F....

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....s, made time deposits of Rs. 36.76 crores and deposited cash of Rs. 10.05 crores including bearer cheques. Since the appellant had not filed return of in spite of having done financial transactions of Rs. 218.42 crores, an order u/s 148A(d) was passed on 29/03/2023. After examining the various submissions filed by the appellant, the AO noted that the source of the source of time deposits of Rs. 38,72,56,429/- made with State of Bank of India was not explained with the help of convincing documentary evidences. Therefore, the AO made addition of Rs. 38,72,56,429/- on account of unexplained investment. During appellate proceedings, the appellant submitted that the details of FDs of Rs. 38,72,56,429/- mentioned by the AO were incomplet....

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....deleted and grounds of appeal raised by the appellant are allowed." In a nutshell, the Ld. CIT(A) held that, * The information relied upon by the Assessing Officer was incomplete and ambiguous. * The Assessing Officer failed to provide branch-wise or account-specific details of the alleged time deposits, despite repeated requests by the assessee. * The assessee obtained a written confirmation from the State Bank of India, confirming that no such FDs existed in the assessee's name during the relevant financial year. * The books of account and bank statements furnished by the assessee did not reflect any such deposits. * The Assessing Officer did not conduct any independent verification or make ....