The assessee, a homemaker having no independent source of income, purchased a residential property for Rs.1.10 crore. In reassessment proceedings, the assessee explained that the entire consideration was paid directly by her father, a businessman and regular income-tax assessee, from his ICICI Bank account to the seller out of natural love and affection. The assessee furnished the sale deed, father’s bank statements, death certificate and details of payments evidencing direct transfer of funds to the seller. The Assessing Officer, however, treated the investment as unexplained u/s 69 on the ground that the source of credits in the father’s bank account was not explained and no formal gift deed was produced. The CIT(A) dismissed the appeal in limine on account of delay. The Tribunal condoned the delay and held that the assessee had fully discharged the primary onus by establishing the immediate source of investment through documentary evidence. The Revenue neither disputed the identity of the father nor the banking transactions. The Tribunal observed that once the payment trail stood established and the source of payment was identified, the absence of a formal gift deed could not render the transaction unexplained, particularly in the context of a father acquiring property in the name of his daughter out of natural love and affection. Mere suspicion regarding antecedent credits in the father’s bank account could not justify addition in the hands of the daughter. Accordingly, the addition was deleted in entirety. (ITA No. 819/Mum/2026, dt. 27-05-2026)( AY. 2016 -17 )