Explained cash deposits from property sale consideration accepted where sale agreement, affidavit and bank evidence supported the assessee's explanation.

Cash deposits in the assessee's bank accounts were held to be satisfactorily explained as sale consideration, including on-money, received from sale of agricultural property. The assessee supported this with the sale agreement, the purchaser's affidavit confirming higher payment, and bank material, while the recorded sale deed showed a lower value. As the Assessing Officer brought no counter-evidence to discredit the explanation or show a different source of funds, the deposits were not treated as unexplained income under section 68 and the addition was deleted.

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Issues: Whether the cash deposits in the assessee's bank accounts were unexplained income liable to be added under section 68, or were duly explained as sale consideration, including on-money, received on sale of agricultural property.

Analysis: The assessee produced the agreement for sale, the purchaser's affidavit confirming payment of the higher consideration, and supporting bank material. The recorded sale deed showed a lower value, but the evidence on record supported the assessee's case that the amounts deposited in the banks represented the actual consideration received from the land transaction. The Assessing Officer did not bring any counter-evidence to show a different source of funds or to discredit the material produced by the assessee. In these circumstances, the explanation for the deposits was accepted as satisfactory.

Conclusion: The deposits were not treated as unexplained income, and the addition was deleted. The Revenue's appeal failed.

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