2026 (7) TMI 1571

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....Shri Pankaj Kumar, CIT DR ORDER PER ANUBHAV SHARMA, JM: This appeal filed by the assessee is directed against the order of Ld. Principal Commissioner of Income Tax (for short, "PCIT)"), dated 25/03/2025 passed under section 263 of the Income Tax Act, 1961 (for short, "Act"), for the Assessment Year (AY) 2020-21. 2. Heard both the sides and perused the record. 3. The assessee has cha....

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.... was made in cash and accordingly Assessing Officer found the cash component to be unexplained and further from the bank payment, amount of Rs.. 5/- Lacs was found to be unexplained, therefore, an addition of Rs.. 41,15,000/- was made. 5. Ld. Revisional Authority, however, concluded that Assessing Officer has not made enquiry with regard to source of the deposit in the bank account which were u....

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....g both the sides and on perusal of material before us, we were quite satisfied with the contention of Ld. AR that Assessing Officer had issued relevant queries and called for relevant documents to reach conclusion that the assessee's source of purchase of the property to the extent of cash component was not explained and even with regard to bank payment also, a part was found to be not explained. ....

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....ence in support of the investment of Rs. 72,05,280/-. Hence, the difference of (72,05,280 - 41,15,000 = 30,90,280) Rs. 30,90,280/- is required to be added u/s. 69 of the Act." 10. Now, if we consider this rectification order dated 19.09.2024, it appears that the same has completely escaped the attention of Ld. Revisional Authority while passing the impugned order under Section 263 of the Act on....