2026 (4) TMI 474

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....utset, ld. Counsel appearing for the assessee, on instructions, did not press ground nos. 1 to 14. An endorsement to this effect was made in the grounds of appeal separately attached to Form No. 36. In view of the aforesaid, ground nos. 1 to 14 are dismissed as not pressed. 3. In ground nos. 15 to 18, the assessee has challenged the addition of an amount of Rs. 2,30,59,100/- made u/s. 69A of the Income Tax Act, 1961 ('the Act' for short). 4. Briefly the facts are, the assessee is a resident individual. The Assessing Officer (A.O. for short) received information that in the financial year relevant to assessment year under dispute, the assessee had purchased an immovable property for a declared sale consideration of Rs. 2,12,00,000/- wi....

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....onstrate availability of accumulated fund. The assessee also furnished a list of candidates with their passport number, address, profession, etc. from whom he had received advances. The A.O., however, did not find the submission of the assessee acceptable. He observed, assessee's story of accumulated fund and advance received from candidates is a make-believe theory, hence, not reliable. Thus, ultimately, he concluded that the source of investment in immovable property remains unexplained. Having held so, he proceeded to add an amount of Rs. 2,30,59,100/- u/s. 69A of the Act. 6. Though the assessee contested the aforesaid addition by filing an appeal before the first appellate authority, however, he was unsuccessful. 7. Before us, the....

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....assessee has furnished copy of wealth tax return for the A.Y. 2011-12. For establishing the advance received from candidates, the assessee had furnished list of candidates with their passport number, address, nature of profession, etc. The assessment order further reveals that it is not a case where the assessee did not comply with the queries raised in course of the assessment proceeding. It may be a case where the assessee failed to make full compliance to the satisfaction of the A.O. Even in course of proceedings before first appellate authority, the assessee did participate. It is a fact on record that the assessee did file wealth tax return to prove availability of accumulation of capital/fund. Whether such accumulated capital/fund was....