The assessee challenged reassessment pursuant to notices issued under sections 148/142(1) on the basis of AIR information regarding alleged investments of Rs. 10 lakh and Rs. 40.95 lakh. During hearing, the assessee relied on documentary evidence placed in the paper book to show that the investment of Rs. 10 lakh pertained to A.Y. 2013–14 and not as wrongly assumed by the Revenue; accordingly, the Tribunal held that the addition of Rs. 10 lakh could not survive. In respect of the alleged property investment of Rs. 40.95 lakh, the Tribunal noted that the sale deed value was only Rs. 35 lakh and that the assessee had availed a housing loan of Rs. 20 lakh from State Bank of India, while the balance of Rs. 15 lakh could reasonably be explained from past savings. As the Departmental Representative failed to controvert the documentary evidence, the Tribunal held that the assessee had successfully dislodged the basis of the addition of Rs. 40.95 lakh. Since relief was granted on merits, the assessee did not press the technical grounds challenging the validity of reassessment. Appeal was partly allowed. ( ITA No. 235/Nag./2024 dt. 23-2-2026) (AY. 2013-14 )
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