The assessee did not file a return of income for A.Y. 2019-20 on the ground that her income was below the exemption limit. She had purchased an immovable property for Rs. 1.56 crores. The AO issued notice under section 148A(b), considered the reply, and thereafter issued notice under section 148. Additions were made of Rs. 1.56 crores under section 69A and Rs. 26.16 lakhs under section 56(2)(vii)(b) for differential value between agreement and market value. In writ proceedings, the assessee contended that funds were provided by her husband directly to the vendor, evidenced by bank statements, and that section 69A applied only to assessees maintaining books of account.. On writ the Court held that, Section 69A applies even where an assessee is not required to maintain books of account, as evident from the words “books of account, if any.” Since the assessee failed to establish that the source funds of Rs. 1.56 crores were reported in her husband’s return of income, the matter was remanded to the NFAC for fresh consideration subject to payment of Rs. 10,000 as costs to Adyar Cancer Institute.  As regards the addition under section 56(2)(x)(b)(B), the Court held that reference in the notice to section 56(2)(vii)(b) instead of section 56(2)(x)(b)(B) did not vitiate the assessment since the provisions were substantially similar, and the differential value exceeded the statutory thresholds. The addition of Rs. 26.16 lakhs was therefore sustained.(AY.  2019-20)