Unexplained investments treated as income when taxpayer fails to satisfactorily explain source, shifting burden to taxpayer and empowering assessing officer discretion.
Clause 103 deems unrecorded investments or amounts exceeding recorded investment as income if the assessee fails to provide a satisfactory explanation to the Assessing Officer; the provision places the evidential burden on the assessee and employs a deeming mechanism to include unexplained amounts in taxable income. Section 69B applies the same explanation-and-deeming approach to investments, bullion, jewellery and other valuable articles where recorded amounts are less than actual expenditure, relying on Assessing Officer evaluation to determine whether excess amounts are to be treated as income.

Unexplained investments deemed income under deeming provision; imposes explanation burden and increased tax scrutiny on taxpayers.
Clause 103 treats investments not recorded in the assessee's books, and amounts exceeding recorded investments, as unexplained unless the assessee provides a satisfactory explanation; such unexplained investments are deemed income for the relevant tax year, subject to the Assessing Officer's evaluation under the clause's deeming provision.