2026 (3) TMI 370

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....39;s case and is contrary to the provisions of Income-tax Act, 1961. 2. Ground 1 is general in nature and do not require adjudication. 3. In the facts and circumstances of the appellant's case the provisions of Section 69A are not applicable. Hence, the addition is liable to be deleted. 4. The Learned Commissioner of Income Tax Appeals has erred in treating Rs. 20,00,000/- as unexplained money u/s. 69A of the Income Tax Act, 1961 which was paid towards outstanding amount on account of purchase of property. This addition is liable to be deleted." 5. The learned Commissioner of Income Tax Appeals erred in invoking the provisions u/s. 69A, while the transaction is duly explained and accounted, recorded, ....

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....horised Representative of the Assessee has also referred to the TDS deducted by the assessee and paid on 31.12.2020 placed at page-79 of the paper book and submitted that once the assessee has paid the outstanding amount in the subsequent year and also paid the TDS along with late fees and interest, then the said addition made by the Assessing Officer is contrary to the record and facts. 4. On the other hand, the learned DR has submitted that as per the sale deed the parties have stated that the total consideration has been paid by the assessee and the receipt of the same is acknowledged by the seller. Therefore, the outstanding of Rs. 20 lakhs claimed by the assessee is not acceptable which is contrary to the facts recorded in the sale ....

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....made by the Assessing Officer based on suspicion that the assessee has already paid this amount at the time of sale deed and showing the outstanding in the balance-sheet is nothing but represents income from unexplained source is not sustainable and the same is deleted. 6. In the result, appeal of the Assessee is allowed. Order pronounced in the open Court on 23.01.2026. ============= Document 1 HDFC BANK We understand your world G K PROPERTIES PVT LTD Customer ID : 31462702 Account Branch : 1555 KARKHANA ROAD - VIKRAMPURI NO.29, GROUND FLOOR P T COLONY KHARKHANA ROAD SECUNDERABAD TELANGANA 500009 RTGS/NEFT IFSC : HDFC0001555 MICR 500240026 : 15552020001083 Account Number Joint Holders 1 Joint Holders 2....