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TMI Blog2025 (5) TMI 1316X X X X Extracts X X X X X X X X Extracts X X X X ..... , CIT (DR) ORDER PER WASEEM AHMED, ACCOUNTANT MEMBER: This appeal has been filed by the assessee against the order passed by the ld. CIT(A)-15, Bengaluru, dated 27/01/2025 in DIN No. ITBA/APL/M/250/2024-25/1072572231(1) for the assessment year 2018- 19. 2. The issue raised by the assessee is that the ld. CIT(A) erred in confirming the addition of Rs. 8,14,412/- representing unexplained asset ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt of Rs. 8,14,412/- was confirmed by the ld. CIT(A), and thus, the appeal of the assessee was partly allowed by the ld. CIT-A. 5. Aggrieved by the order of the ld. CIT(A), the assessee is now in appeal before us. 6. The ld. AR before us filed a paper book running from pages 1 to 47 and a case law compilation containing pages from 1 to 226. The ld. AR fairly agreed that no direct correlation bet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... contentions of both the parties and perused the materials available on record. It is an admitted fact that the assessee declared income falling under the higher tax bracket. The income declared over the years is sufficient to justify the impugned investment in gold. In this context, reference is made to the order of the Delhi Tribunal in the case of Kirti Singh Vs. ACIT (ITA No. 1067/Del/2023), wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cept for the impugned investment in gold. Therefore, the value of the unexplained gold is insignificant compared to the declared income. Accordingly, we set aside the findings of the ld. CIT(A) and direct the AO to delete the addition. The assessee's ground of appeal is allowed. 8.2 Regarding the ground challenging the validity of the assessment under section 143(3) of the Act, the ld. AR stated ..... X X X X Extracts X X X X X X X X Extracts X X X X
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