Johnson Praveen Quadros Australia Vs ITO (ITAT Mumbai)
Sec 69 Addition Deleted – NRI Property Investment Explained Through Overseas Remittances & Mother’s Bank Trail – ITAT Mumbai
AO reopened assessment alleging unexplained investment of ₹14.70 lakh u/s 69 towards purchase of immovable property by NRI assessee and invoked Sec 115BBE. Assessee explained that funds were sourced from overseas earnings transferred to mother’s account and later utilised for property purchase; documentary evidence including bank trail, term deposits and maturity proceeds were furnished.
ITAT held that trail of funds routed through mother was fully supported by documentary evidence and relationship was established through passport records. Tribunal observed that payments through mother represented utilisation of assessee’s own remitted funds and source stood explained. Accordingly, addition u/s 69 was deleted and appeal allowed
FULL TEXT OF THE ORDER OF ITAT MUMBAI
1. This appeal filed by the assessee is against the final assessment order passed by the Assessing Officer u/s.147 r.w.s. 144C(13) of the Act dated 28.08.2025, pursuant to the direction issued by the ld. Dispute Resolution Panel – 1, Mumbai vide order dated 28.07.2025 vide order no. ITBA/DRP/F/144C(5)/2025-26/1078981626(1) dated 28.07.2025 u/s. 144C(5) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), for AY 2017-18.
