Jora Ram Mali Vs. ACIT, Circle – 4(2)

Parties Involved

Facts Summary

The present appeals have been preferred by the assessee, Jora Ram Mali, against the orders dated 16.09.2025 passed by the National Faceless Appeal Centre / CIT(A), Mumbai for the Assessment Years 2018-19 & 2019-20. The appeals involve common and identical issues and have been consolidated for hearing. The main contentions of the assessee include the invalidity of proceedings under section 153C, lack of incriminating material, unauthenticated electronic evidence, and the burden of proof not being discharged by the department. Additionally, the assessee argued that the registered agreement value was higher than the stamp duty value, indicating a bona fide transaction. The assessee also highlighted that they were ex-parte before the Ld. CIT(A) and that the CIT(A) failed to consider the documents filed by the assessee.…

Legal Issues

• 1. Erroneous confirmation of addition of 27,15,625/- as unexplained investment under section 69 of the Income-tax Act, 1961.
• 2. Invalid jurisdiction under Section 153C.
• 3. No incriminating material relating to the appellant.
• 4. Unauthenticated electronic evidence.
• 5. Burden of proof not discharged by the department.
• 6. Violation of Section 292C presumption.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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