2025 (4) TMI 1954

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... : Ms. Urvashi Sodhan, AR. For the Respondent : Smt. Trupti Patel, Sr. DR ORDER PER SHRI NARENDRA PRASAD SINHA, AM: This appeal is filed by the assessee against the order of the Commissioner of Income Tax (Appeals), Ahmedabad-13, (in short 'the CIT(A)'), dated 11.08.2023 for the Assessment Year 2011-12. 2. As per registry, there was a delay of 39 days in filing of this appeal. The a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....asis of information that the assessee had made investment in Mutual Funds, reopened the case under Section 147 of the Income Tax Act, 1961 (in short 'the Act'). In the course of assessment, there was no compliance made by the assessee. Therefore, the AO treated the entire investment of Rs. 1,44,71,816/- in SBI Mutual Fund as undisclosed income of the assessee. Accordingly, the assessment was compl....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....4,71,816/- of investment made in Mutual Funds from NRI external a/c as unexplained investment u/s 68 of the Act. 3. It is respectfully submitted that an opportunity be granted to the appellant to submit all relevant documents before the revenue authorities to substantiate the fact that no tax is required to be paid since investments in Mutual Funds were made from NRI account. 4. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... before the appellate authority. She further submitted that the entire investments in SBI Mutual Fund was made out of bank account of the assessee and, therefore, the AO was not correct in treating the same as unexplained investment. The assessee has also filed an application for admission of additional evidence in support of the investment made in Mutual Funds. The Ld. AR, therefore, requested th....