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2025 (6) TMI 1397 - AT - Income Tax


The Appellate Tribunal (ITAT Cochin) allowed the assessee's appeal against the addition of Rs. 18,41,000/- made u/s 69A of the Income Tax Act for AY 2015-16. The Assessing Officer had added this amount due to a discrepancy between the actual sale consideration (Rs. 34,00,000/-) and the registered sale deed value (Rs. 15,59,000/-) for two agricultural properties. The Tribunal held that under section 69, the onus lies on the assessee to explain the nature and source of credited money. The assessee discharged this burden by demonstrating through bank statements that the full amount was received via transparent banking channels and that the lower registered value resulted from the purchaser's choice to register at the circle rate for stamp duty purposes, a practice beyond the assessee's control. Since the revenue failed to prove the funds originated from unaccounted sources, the addition was "unsustainable." The Tribunal directed deletion of the addition, stating the assessee had proved "the identity of the buyer, genuineness of the transaction and source of fund," thereby satisfying the requirements of section 69. The appeal was allowed.

 

 

 

 

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