ITAT Deletes Rs. 32 Lakh and Rs. 3.60 Lakh Additions on Property Purchase; Upholds Father’s Savings as Source
The Tribunal deleted the additions of Rs. 32 lakh and Rs. 3.60 lakh made by the tax authorities under Sections 69/69C, holding that the property purchase funds were from her father’s genuine savings, and allowed the taxpayer’s appeal in full.
Padmakshi Chakraborty has filed the present appeal in the ITAT Kolkata, challenging an order dated September 13, 2025, passed by the CIT(A)/NFAC. The impugned order had confirmed additions of Rs. 32 lakhs and Rs. 3.60 lakhs made by the Assessing Officer (AO) under Sections 69 and 69C of the Income Tax Act 1961, in relation to a property purchased by the assessee. The case is related to the Assessment Year 2020-2021.
During the year in consideration, the assessee had purchased a property worth Rs. 32 lakhs. The market value of the property as per the registration was Rs. 4,689,600. On which, the assessee paid a stamp duty of Rs. 360,307. The assessee also received interest income amounting to Rs. 32,908 and Rs. 25,990 from Indian Overseas Bank and Bank of Baroda, respectively. During the assessment proceedings, the assessee did not furnish relevant evidence of the source of funds amounting to Rs. 32 lakhs (purchase of property) and Rs. 360,307 (stamp duty). In conclusion, the AO treated the said funds as unexplained expenditure and made the addition of the same to the assessee’s income.
The assessee filed an appeal before the ITAT Kolkata, where she argued that the property in question was purchased in joint ownership with her mother, and the funds for the purchase were provided by her father, who is 83 years old. He used to work at Hindustan Cables Ltd. and retired on October 31, 1996, after 34 years of service. His income was the only salary accumulated over the years. They had never filed any ITR, as the income was not taxable. Further claimed that, as it’s been 29 years since his retirement, it is not possible to gather all the retirement papers and receipts.
The assessee further claimed that full details were available to explain the source of the funds used to purchase the property. The total amount used was Rs. 3,200,000, including the purchase price and other related expenses. When the tribunal verified the facts of the case, it noted that the reasons and evidence furnished by the assessee were genuine and valid. Therefore, the Tribunal set aside the impugned CIT(A)’s order and deleted all the additions made by the AO under Sections 69 and 69C of the Income Tax Act. As a result, the appeal filed by the assessee was allowed in full.
Citation: Padmakshi Chakraborty Vs ITO (ITAT Kolkata); ITA No.2279/KOL/2025; 23/12/2025; 2020-2021
