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Judgment
This assessee’s appeal for assessment year 2012-13, 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/250/2025-26/1084050493(1), dated 24.12.2025 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
Delay of 146 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).
Learned counsel canvasses the assesse’s sole substantive ground on merits challenging the learned lower authorities’ action making section 69 unexplained investment(s) in property (ies) amounting to Rs. 43,85,250/- which forms the sole subject matter for the tribunal’s apt adjudication herein.
That being the case, the assesse invites the tribunal’s attention to the loans received from Sri Anshul Jain, Sh. Anil Kumar involving Rs. 23.90 lacs and 4,00,000/- followed by motor car sale receipts of Rs. 6 lacs and agricultural income of Rs. 18,98,500/-, respectively all duly supported by the corresponding bank statements, repayments, receipts and “J” - form which have gone unrebutted from the Revenue side. I hold in these facts and circumstances that the assesse has very well explained the source of his impugned investments amounting to Rs. 43.85 lacs and the same could not have been treated as unexplained by learned departmental authority. The impugned additions is directed to be deleted therefore.
The assessee’s appeal is allowed.