Registered sale deeds prevail over uncorroborated oral statements where the Revenue fails to prove understatement of consideration.

Addition under section 69 cannot be sustained merely on oral statements of sellers when registered sale deeds record the consideration and no corroborative material links alleged cash deposits to the assessee. The note states that, absent an agreement to sell, supporting witness statements, or independent evidence of payment over and above the documented price, the documentary record prevails and the burden to prove understatement of consideration remains on the Revenue. A presumptive inference cannot replace proof, and the addition was deleted in favour of the assessee.

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Issues: Whether an addition under section 69 of the Income-tax Act could be sustained solely on the basis of oral statements of the sellers, ignoring the registered sale deeds and the absence of corroborative material linking the cash deposits in the sellers' accounts to the assessee.

Analysis: The assessee had purchased land under registered sale deeds which recorded the consideration and were signed by the parties and witnesses. The Revenue relied mainly on statements of the sellers and on cash deposits in their bank accounts, but did not bring on record any agreement to sell, corroborative witness statements, or independent material establishing that the assessee had paid consideration over and above the amount stated in the documents. The documentary evidence in the registered deeds, together with the assessee's explanation and affidavits, outweighed the uncorroborated oral statements. The burden to show understatement of consideration and nexus with the cash deposits remained undischarged. A presumptive inference could not replace proof.

Conclusion: The addition under section 69 was not sustainable and was deleted in favour of the assessee.

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