Section 69B cannot be invoked on mere assumption that there was understatement of investment

DCIT Vs M/s Riar Builders Pvt. Ltd. (ITAT Amritsar) Section 69B cannot be invoked on the assumption that there was understatement of the investment, without a finding that the assessee invested more than what was recorded in the books of account. Sec. 69B does not permit an inference to be drawn from the circumstances surrounding the transaction that the purchaser of the property must have paid more than what was actually recorded in his books of account for the simple reason that such an inference could be very subjective and could involve the dangerous consequence of a al or fictional incom...