The assessee had not filed a return of income for A.Y. 2019-20 on the ground that her income was below the exemption limit. She purchased an immovable property for Rs. 1.56 crores, which triggered reassessment proceedings under section 148A. Additions were made of Rs. 1.56 crores under section 69A and Rs. 26.16 lakhs under section 56(2)(vii)(b) [later applied as section 56(2)(x)(b)(B)] being the differential between agreement value and stamp duty value. On a writ petition, the Court held that section 69A applies even where the assessee is not required to maintain books of account. Though the Assessing Officer was prima facie satisfied with the explanation regarding the source of Rs. 1.56 crores, the assessee failed to produce her husband’s return of income and relevant documents. The matter was remanded to NFAC for fresh consideration of the section 69A addition, subject to payment of Rs. 10,000 as costs to Adyar Cancer Institute. The addition of Rs. 26.16 lakhs under section 56(2)(x)(b)(B) was upheld as valid.(AY. 2019-20)