TaxTMI 
TaxTMI 
2026 (3) TMI 785
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....erit is concerning the addition of an amount of Rs. 6,60,37,500/- u/s. 69 of the Act, representing alleged unexplained investment in purchase of immovable property. 3. Briefly, the facts are, the assessee is a resident individual. For the assessment year under dispute, the assessee did not filed her return of income, since, she did not have any reportable income. 4. Subsequently, the Assessing Officer ('A.O.' for short) received information that in the year under consideration, the assessee had purchased an immovable property investing huge amount. Whereas, she had not filed any return of income. Alleging escapement of income, the A.O. reopened the assessment u/s. 147 of the Act. In course of assessment proceeding, the A.O. called upo....
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.... 13,20,75,000/-, at the hands of the assessee by treating it as 'unexplained investment' u/s. 69 of the Act. 5. Though the assessee contested the addition before ld. First appellate authority, however, she was unsuccessful. 6. Before us, ld. Counsel appearing for the assessee drew attention to the copy of the sale deed placed in the paper book and submitted that since the husband was NRI, assessee's name was added as joint owner while executing the sale deed. Drawing our attention to the schedule of payment mentioned in the sale deed, ld. Counsel submitted, the entire payment was sourced through assessee's husband Late Anil Kapoor. In this context, he drew our attention to copy of joint bank account in the name of the assessee and her....
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....f Rs. 17,35,00,000/-. In fact, in course of assessment proceeding, the assessee had furnished the entire break up of payments with source along with the copies of bank statements. The source of investment has been explained as under: Mr. Anil Kapoor Details of Purchase of Flat in AY 2013-14 Particulars Flat No.42, 4th Floor, Mont Blanc, Dadyseth Hill, August Kranti Marg, Mumbai-400 036 Payment Details Date Cheque Amount Pg.Ref.No. Add :- Date of Purchase 05-06-2012 Date of Registration 05-06-2012 Cost of Property 17,35,00,000 13-03-2012 930327 1,67,00,000 Pg-1/5 Bank Cha....
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....perusal of bank statements placed before us, it is noticed that an amount of Rs. 5,01,00,000/- has come from BNP Paribus Short Term Income Fund, whereas Rs. 8,38,50,000/- was paid through the joint account held by the assessee and his husband in HSBC Bank, having been transferred from fixed deposits standing in the name of Late Anil Kapoor for an amount of USD 15 lacs. Another amount of Rs. 9 crores has been credited to the said bank account out of the withdrawal. Thus, the entire source of investment in the purchase of property stands explained through the bank accounts alone. Admittedly, all these documentary evidences were furnished before the departmental authorities. It is also a fact that assessee's husband Late Anil Kapoor had died p....