2026 (1) TMI 753

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....ssessment order passed by Assessing Officer u/s. 147 of the Act, on 16.03.2025. 2. Grounds of the appeal raised by the assessee are as under: 1. The Ld. CIT(A) erred in not adjudicating the addition of 280,000 made under section 69A, based on a third-party ledger lacking any reference to the assessee, without independent corroboration, ignoring the possibility of fabrication, and contrary to valuation accepted by the Stamp Valuation Authority. 2.The Ld. CIT(A) erred in not adjudicating the addition made without any evidence of additional source of income to justify the alleged unexplained investment. 3. The Ld. CIT(A) erred in confirming the addition based merely on assumptions and suspicion, without any conclu....

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.... the Act. Therefore, assessment is completed u/s 147 r.w.s. 144B of the I.T. Act, 1961 at assessed income of Rs. 3,25,930/- (Rs. 2,45,930/- as per ITR u/s 148 + Rs. 80,000/- u/s 69A). 4. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the CIT(A), who has confirmed the action of the Assessing Officer, therefore, assessee is in appeal before this Tribunal. 5. Learned Counsel for the assessee, at the outset submitted that required documents and evidences were submitted by the assessee before the assessing officer to prove his claim. However, only addition made by the A.O. is to the tune of Rs. 80,000/- therefore, considering the smallness of the amount an estimated addition @ 10% should b....