Burden of proof for cash deposits: unsupported donation claim failed, section 68 addition sustained and no substantial question arose.

Cash deposits claimed as third-party donations were not proved by reliable evidence, so the assessee failed to discharge the burden of explaining the entries and source of funds under the Income-tax Act. A supporting affidavit was insufficient because the deponent was not produced for cross-examination and the surrounding circumstances were inconsistent with the explanation offered. The factual findings of the Assessing Officer and Tribunal were based on appreciation of evidence and were not shown to be perverse, so the addition under section 68 was sustained and no substantial question of law arose.

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Issues: Whether the addition made on account of cash deposits claimed to be donations collected on behalf of a third person was liable to be deleted, and whether the findings of fact recorded by the lower authorities were perverse so as to give rise to a substantial question of law.

Analysis: The assessee failed to establish the genuineness of the alleged donations with reliable evidence. The person whose affidavit was relied upon was not produced for cross-examination despite opportunity, and the surrounding circumstances were found inconsistent with the version put forward. In proceedings under the Income-tax Act, the burden to explain entries in the bank account and the source of the cash deposits lies on the assessee, and a mere explanation or a third-party affidavit, without supporting evidence, does not discharge that burden. The factual conclusions reached by the Assessing Officer and the Tribunal were based on appreciation of evidence and were not shown to be erroneous or perverse.

Conclusion: The addition under section 68 was sustained and no substantial question of law arose.

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