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48. (2026) 188 taxmann.com 871 (Mum Trib)
Hotel Mahalaxmi v. ITO
A.Y.: 2018-19 Date of Order: 16.07.2026
Section: 69
Where the assessee-firm revalued its existing tenancy/leasehold rights in its business premises on the basis of a Government-approved valuer's report, crediting the differential to partners' capital accounts without acquiring any new asset, introducing funds, paying consideration to any third party, or claiming depreciation on the revalued amount, such a book revaluation could not be treated as unexplained investment under section 69.
FACTS
The assessee, a partnership firm engaged in running a hotel/restaurant, had been in continuous possession and occupation of its business premises under tenancy/leasehold rights since 1984. During the relevant year, it revalued the existing tenancy/leasehold rights on the basis of a report by a Government-approved valuer and recorded the revaluation by debiting the fixed asset account and crediting the partners' capital accounts. No new asset was acquired, no funds were introduced, no consideration was paid to any third party, and no depreciation was claimed on the revalued am
