TMI Blog2019 (3) TMI 1026X X X X Extracts X X X X X X X X Extracts X X X X ..... t on protective basis - assessee relied mutual funds are purchased by mother of her husband Shri Nirmal Kumrawat in the name of Smt. Rozina Kumrawat. The same is shown in the return of income of the assessee’s mother Smt. Rozina Kumrawat - HELD THAT:- In so far as the investment in respect of PNB Principal Asset Management Fund is concerned, The assessee has failed to explain source of the investment of his mother. He has only simply said that his mother has invested in his name. The Ld. CIT(A) confirmed the order of the A,O. In this case, the assessee failed to discharge the burden cast upon him by producing the relevant material that his mother has made an investment - assessee appeal is dismissed. In so far as investment made in SBI Mutual funds in the name of Smt. Marry Rozina Kumrawat, wife of the assessee is concerned, it was submitted that the assessee’s mother has purchased the units in the name of the assessee’s wife Marry Rozina Kumrawat. Neither before the A.O. nor before the Ld. CIT(A) the assessee is able to substantiate that the his mother is having sufficient funds to purchase the units. Therefore, both the A.O. and Ld. CIT(A) disbelieved the investment made by h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubmitted that no addition can be made. Ld. CIT(A) has not accepted the explanation of the assessee and confirmed the addition made by the A.O. 3. On appeal before us, the Ld. Counsel for the assessee has submitted that the assessee has not made any investment in the small savings scheme of Rajasthan and therefore, addition cannot be made. 4. On the other hand, Ld. .D.R. strongly supported the order passed by the authorities below. 5. We have heard the rival submissions, perused the materials available on record and gone through the orders of the authorities below. Ground Nos.1 2 are not pressed and the same are dismissed as not pressed. The only issue involved in this appeal relates to addition of ₹ 6 lakhs. There is a search conducted and in the course of search, a suit case belonging to the assessee was found. In the suit case 120 lottery coupons of Rajasthan State Government were found. It was submitted during the course of search that assessee has not made any investment in the small savings scheme of the Rajasthan Government and therefore no addition can be made. During the course of assessment proceedings, the AO. has asked the assessee that there were 120 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bank account No.4041000004077 HDFC bank, Indore. The aforesaid investment is not reflected in the return of income of the assessee. In response, the assessee has replied that these mutual funds are purchased by mother of the assessee in the name of the assessee. On verification from IT return of mother of Shri Nirmal kumrawat, the A.O. noted that it does not appear that she has regular source of income from which she has earned so much of liquid funds that could be advanced to any of the persons neither any outstanding balance is reflected in the balance sheet nor the same has been repaid the amount of cash taken from his mother. Therefore, the assessee s submissions are not genuine, tenable. Apart from this, cheques to purchase such mutual funds so issued from the bank account of Shri Nirmal Kumrawat. These investments made by Shri Nirmal Kumrawat are treated to be his income from undisclosed sources added to his total income on substantive basis in case of legal descendant of late Smt. Rozina Kumawat on protective basis. 9. There is one more addition made by the A.O. in respect of ₹ 45,000/-. The A.O. noted that as per the accounts statement dated 30.6.2005 of the Pu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an investment. We find no reason to interfere into the order of the Ld. CIT(A) and the ground raised by the assessee in this appeal is dismissed. So far as the investment in PNB Principal Asset Management Mutual Fund relates to ₹ 45,000/- in the name of Smt. Mary Razina Kumawat wife of the assesse is concerned, the mother of the assesse has purchased and further purchased the mutual funds.However, they have not filed any details such as source of investment, etc. The A.O. made an addition. Ld. CIT(A) confirmed the same. Even before us, the assesse has not filed any details before us in respect of investments made by the assessee s mother by purchase of PNB Principal Asset Management Mutual Fund in the name of wife of the assesse Smt. Mary Rezina Kumawat. We find no reason to interfere and dismiss the appeal 10. In so far as investment made in SBI Mutual funds in the name of Smt. Marry Rozina Kumrawat, wife of the assessee is concerned, it was submitted that the assessee s mother has purchased the units in the name of the assessee s wife Marry Rozina Kumrawat. Neither before the A.O. nor before the Ld. CIT(A) the assessee is able to substantiate that the his mother is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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