Unexplained investment additions can stand where higher consideration is admitted and corroborated by contemporaneous evidence.

An addition for unexplained investment under section 69 can be sustained where an admission of higher consideration is supported by contemporaneous statements, a written confirmation of the sale price, corroborating bank credits, and tax paid on the admitted receipts. The Tribunal's deletion of the additions was found perverse because it ignored this evidence, and the assessments were restored in favour of the Revenue. The purchasers had been offered cross-examination of the sellers but declined it, reinforcing the evidentiary basis for sustaining the assessments.

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Issues: Whether the Tribunal was justified in cancelling the assessments made under section 69 on the ground of unexplained investment in the purchase of property.

Analysis: The assessments were based on the seller's contemporaneous statements, a written letter confirming the higher sale consideration, corroborating bank credits, filing of return, and payment of tax on the admitted receipts. The purchasers were given an opportunity to cross-examine the sellers but declined it. On the evidence, the Tribunal's view that the additions could not stand was held to be unrealistic and perverse.

Conclusion: The Tribunal was not justified in deleting the additions under section 69, and the assessments were restored in favour of the Revenue.

Ratio Decidendi: Where an admission of higher consideration is supported by corroborative material, an addition for unexplained investment under section 69 can be sustained and a contrary finding that ignores such evidence is perverse.

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