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Judgment
This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1084457802(1), dated 06.01.2026 involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Delay of 53 days in filing of the assessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
It transpires during the course of hearing that the assessee/appellant is aggrieved against both the learned lower authorities’ respective assessments and the lower appellate findings holding her investments in debentures amounting to Rs.21.77 lakhs as unexplained under section 69A of the Act which forms the sole subject matter of the tribunal’s apt adjudication both.
Both the parties vehemently reiterate their respective stands against and in support of the impugned addition. Coming to the source of the impugned investment, learned counsel invited the tribunal’s attention to the assessee’s bank statement indicating her closing balance as on 31st Marh, 2018 amounting to Rs.14,56,189/- thereby forming opening balance as on 01.04.2018 which followed the deposits of Rs.51,000/- and investments made on 11.04.2018 with M/s. Muthoot Finance to the tune of Rs.15 lakhs. This followed yet another investments of Rs.10 lakhs made on 28th March, 2019. There is no entry in the said bank statement which has been held as unexplained in both the lower proceedings. It is thus concluded that the assessee has successfully proved the source of her impugned investments as her savings in her bank account, which could not be treated as unexplained in her hands. Deleted accordingly.
This assessee’s appeal is allowed.