2026 (4) TMI 645

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....ome-tax Act, 1961 (hereinafter referred to as the "Act" for short) for Assessment Year 2015-16. 2. The assessee has raised following grounds of appeal :- "1. On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in making addition of Rs. 1,24,57,286/- on account of credit entry treating as an income and taxed u/s. 115BBE of the Income Tax act, 1961. 2. On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer not justify in making addition of Rs. 31....

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....immovable property, and ownership of commercial properties without declaring rental income. The Assessing Officer completed the assessment under section 143(3), making additions as follows: i. Rs. 1,24,57,286/- on account of unexplained bank credits. ii. Rs. 31,18,974/- on account of unexplained investment in immovable property. iii. Rs. 12,20,000/- on account of deemed rental income from commercial properties. iv. Rs. 6,90,909/- on account of suppression of receipts. The total assessed income was determined at Rs. 1,78,79,190/-. 3.1 Aggrieved by the order of the Assessing Officer, the assessee filed an appeal before the CIT(A), challenging these additions, claiming that bank credits were business r....

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....sed bank accounts. Accordingly, the Assessing Officer is directed to restrict the addition to 8% of Rs. 1,24,57,286/- and the addition of balance amount is deleted. The appeal of the assessee on this ground is accordingly is partly allowed. Ground No. 2: Addition of Rs. 31,18,974/- on account of unexplained investment 7. The Assessing Officer added an amount of Rs. 31,18,974/- under section 68 of the Act, treating it as unexplained investment. The assessee submitted that Rs. 29,44,350/- was paid in F.Y. 2015-16 and the balance Rs. 1,74,624/- was from current business income and withdrawals from partnership firms, namely M/s Radhe Tex Fab, M/s Sai Krupa Tax, Meera Tex Fab, M/s Vishwa Creation, and Mrs. Arunaben H. Panchani. However,....