Sec. 69A & 153 of Income Tax act, 1961 - Unexplained Investment - Since the assessment proceedings no longer involve human interaction and is based on records alone, the assessment proceeding should have commenced much earlier so that before passing assessment order, the AO could have come to a definite conclusion on facts after fully understanding the nature of business of the petitioner. It appears that the return of income was filed by the petitioner on 02.11.2017. However, the assessment proceeding commenced much later towards the end of the period prescribed under section 153 of the Act, 1961. Hence, assessment proceeding under the changed scenario would require proper determination of facts by proper exchange and flow of correspondence between the petitioner and the AO. Thus, the impugned order is set aside and the case is remitted back to the respondent to pass a fresh order. - SALEM SREE RAMAVILAS CHIT COMPANY (P) LTD. V/s DEPUTY CIT - [2020] 273 TAXMAN 068 (MAD)