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Issues: Whether the assessee had satisfactorily explained the source of the cash balance and bank deposits by relying on an alleged higher sale consideration for agricultural land, despite the registered sale deeds reflecting a lower consideration.
Analysis: The alleged sale agreement was on plain paper, was unregistered, and was not signed by the purchaser. The land transactions were covered by registered sale deeds showing consideration of Rs. 2.04 lakhs, and no reliable evidence was produced to show payment of Rs. 12 lakhs. The registered documents were treated as the conclusive evidence of the transaction, and oral or uncorroborated contrary material could not displace their terms. The agreement relied on by the assessee was therefore treated as unreliable and self-serving. The cash balance claimed to arise from the higher alleged consideration remained unsubstantiated.
Conclusion: The source of the cash balance and deposits remained unexplained, and the addition was rightly sustained.
Final Conclusion: The appeal failed because the assessee could not dislodge the consideration recorded in the registered sale deeds with any credible evidence, and the impugned addition was upheld.
Ratio Decidendi: When a registered conveyance fixes the consideration and no dependable evidence supports a higher unregistered claim, the registered document prevails and the contrary amount cannot be accepted as the source of funds.