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2. The assessee is an individual residing in Qatar. The AO received an information from DCIT Central Circle-1(3), Mumbai that during the search action conducted by the Department in the group concerns of M/s Bhagwati Developers incriminating materials have been found containing the details that the assessee has paid Rs. 25,00,000/- in cash during the Financial Year (FY) 2014-15 to M/s Shanti Enterprises belonging to the group of M/s Bhagwati Developers for the purchase of an immovable property being Flat No.B-604, 6th Floor, Sky Oasis, Plot No. 29, sector-9, Ulwe, Navi Mumbai. The AO re-opened the assessment based on the above information by issuing a notice under section 148 of the Act on 30.06.2021 stating that he had reason to believe that the income chargeable to tax has escaped assessment. The assessee did not file any return in response to the notice under section 148 of the Act. Subsequently as per the directions of the Hon'ble Supreme Court as rendered in the case of Ashish Agarwal Vs. Union of India [2022] 138 taxmann.com 64 dated 04.05.2022 the AO issued a notice under section 148A(b) dated 25.05.2022 calling on the assessee to file necessary response. The AO after passing the order under section 148A(d) issued notice under section 148 dated 22.07.2022 re-opening the assessment of the assessee. The assessee did not file any return in response to the said notice also. The assessee however filed submissions in response to the various notices issued by the AO under section 142(1) of the Act. The assessee submitted that she has purchased the impugned property from the builder M/s Shanti Enterprises which is a group concern of M/s Bhagwati Developers for an agreement value of Rs. 35,10,000/- out of her savings from the salary income as she was employed with Qatar Commercial Bank and the assessee filed the supporting documents such as registration receipt, payment receipt, bank statements, etc. before the AO in this regard. The assessee further submitted that she has not paid any cash to the builder and the entire consideration paid was only Rs. 35,10,000/-. The AO did not accept the submissions of the assessee for the reason that the incriminating materials seized during the course of search contained certain documents where it has been mentioned a sum of Rs. 60,10,000/- as amount received towards sale of the impugned flat. Since the assessee did not file any further details, the AO proceeded to treat the difference amount of Rs. 25,00,000/- (Rs. 60,10,000 - Rs. 35,10,000) as unexplained investment and made addition accordingly.