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2023 (6) TMI 339 - AT - Income TaxUnexplained investment in property - Addition u/s 69 - HELD THAT:- As u/s 69 of the Act, all that is required, is to explain the source of investment and the source of investment in the impugned property is the Euros received from Ms. Diana Perrone. No substance in the observations of the revenue authorities that the assessee has failed to explain the source of investment. AO is, accordingly, directed to delete the impugned addition - This ground is, accordingly allowed. Disallowance of 20% business expenses - CIT(A) enhancing addition to 100% receipts as unexplained income - HELD THAT:- Whenever the question of taxability of income from new source of income is concerned, which had not been considered by the Assessing Officer, jurisdiction to deal with the same in appropriate cases may be dealt with u/s 147/148 of the Act and u/s 263. It is unconceivable that in the presence of such specific provisions a similar power is available to the first appellate authority - we do not find any merit in the addition made by the ld. CIT(A) and the same is directed to be deleted. This Ground is allowed
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