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Issues: (i) Whether the receipt of Rs. 50,00,000 was liable to addition as unexplained cash credit on the allegation that it was an accommodation entry; (ii) Whether an addition for alleged commission expenditure on the purported accommodation entry was sustainable.
Issue (i): Whether the receipt of Rs. 50,00,000 was liable to addition as unexplained cash credit on the allegation that it was an accommodation entry.
Analysis: The addition rested principally on general search material concerning alleged entry providers and the characterisation of the payer as a paper entity. The assessee produced an executed agreement concerning sale of immovable property, bank statements, tax-return acknowledgement of the payer, ledger confirmation, payment records, correspondence, and material showing that a genuine buyer was arranged and the deposit was refunded in accordance with the agreement. The material established commercial substance, whereas no direct evidence connected this specific receipt with an accommodation-entry arrangement.
Conclusion: The receipt was not an unexplained cash credit; deletion of the addition was sustained in favour of the assessee.
Issue (ii): Whether an addition for alleged commission expenditure on the purported accommodation entry was sustainable.
Analysis: The commission addition was founded solely on the premise that the assessee had availed an accommodation entry. Since that premise did not survive, the consequential presumption of commission payment had no factual basis.
Conclusion: The addition for alleged commission expenditure was unsustainable; its deletion was sustained in favour of the assessee.
Final Conclusion: The documentary evidence established the commercial reality of the transaction and displaced the unsupported inference of an accommodation entry, with no basis remaining for the consequential commission addition.
Ratio Decidendi: An addition for unexplained credit cannot rest on general allegations concerning an alleged entry provider where cogent transaction-specific documentary evidence establishes the genuine commercial character of the receipt; a consequential commission addition then cannot survive.
Unexplained cash-credit additions fail where transaction-specific evidence proves commercial substance and defeats alleged accommodation-entry assumptions.
Unexplained cash-credit additions based on alleged accommodation entries require transaction-specific evidence. Where an executed property-sale agreement, banking records, payer tax records, confirmations, payment documentation, correspondence, and contractual refund evidence establish commercial substance, general search material concerning purported entry providers does not justify treating the receipt as unexplained. A commission-expenditure addition premised solely on the alleged accommodation entry also lacks a factual basis once the underlying receipt is shown to be genuine. The additions were therefore deleted.
Unexplained cash credit - property sale deposit - Consequential commission expenditure for accommodation entries Unexplained cash credit - property sale deposit - Addition as unexplained cash credit in respect of the amount received from an alleged entry-provider company under an agreement concerning sale of immovable property - HELD THAT: - The assessee produced the executed agreement, bank statements, income-tax return acknowledgement of the payer, ledger confirmation, and documents showing that a buyer was arranged and the deposit was refunded in accordance with the agreement. The addition rested on general third-party material and the alleged status of the payer as a paper company, without concrete material directly linking the assessee's receipt to an accommodation entry. Such presumption could not displace the documentary evidence establishing the commercial reality of the transaction. [Paras 7] Deletion of the addition under section 68 was affirmed. Consequential commission expenditure for accommodation entries - HELD THAT: - Since the underlying receipt was not held to be an accommodation entry, the assumed payment of commission for obtaining such entry had no factual basis. [Paras 8] Deletion of the consequential addition under section 69C was affirmed. Final Conclusion: The Revenue's appeal was dismissed, affirming deletion of the unexplained-credit addition and the consequential estimated commission addition for AY 2018-19.