The assessee purchased a property at Rs. 27.80 crore and recorded the same at only Rs. 14 crore. The remaining 13.8 crore was withdrawn out of the bank account of a sister concern and paid in cash to the seller for which the sister concern received no share of the property. The AO made addition under section 69B of unexplained investment of Rs. 13.8 crore. The CIT(A) granted relief to the assessee by deleting the addition made. On departments’ appeal before the Hon’ble ITAT, the assessee contended that it has successfully proved the source of Rs. 13.8 crore being amount reflecting the books of its sister concern. However, the Hon’ble ITAT held that as the assessee had accepted that the value of the property purchased was Rs. 27.80 crore, the onus was upon the assessee to prove the amount expended in the books of account maintained by the assessee and not the books of the sister concern. Since the assessee was unable to prove the same from its books of accounts, the Hon’ble ITAT upheld the addition made by the AO.  (AY. 2009-10)