No addition for unexplained investment on basis of unsigned MOU recovered during survey for purchase of land

Section 69, read with section 271(1)(c), of the Income-tax Act, 1961 - Unexplained investments (Immovable properties) Assessment year 2006-07 - An unsigned memorandum of understanding between assessee and a seller of land as well as an unsigned receipt issued by seller was recovered - Said MOU as well as receipt in question were found to be unsigned documents and transaction had not materialized - Whether since both Commissioner (Appeals) and Tribunal found that facts did not establish revenue's contention that unexplained investment in cash had been made by assessee, no question of law arose from order of Tribunal deleting addition on that account - Held, yes [Para 6] [In favour of assessee]

Refer:[2014] 46 taxmann.com 372 (Delhi)

HIGH COURT OF DELHI

Commissioner of Income-tax

v.

Gian Gupta