Unexplained cash receipt upheld where a corroborated loose paper matched the registered sale deed and proved unrecorded consideration.

A loose paper found during survey, containing itemised entries of sale consideration, cheque payments and a cash component for transfer of land and machinery, was treated as corroborated evidence because it matched the registered sale deed in parties, property details, cheque numbers, dates and amounts. The partner's admitted handwriting and the surrounding transaction circumstances supported the inference that the paper reflected the actual deal, not a mere proposal. The absence of physical cash during survey did not negate the document's evidentiary value where the assessee failed to rebut its contents satisfactorily. The addition as unexplained cash receipt under section 69A was therefore upheld.

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Issues: Whether the amount treated as unexplained cash receipt on the basis of the handwritten loose paper could be sustained under section 69A of the Income-tax Act, 1961.

Analysis: A loose paper found during survey contained detailed entries of the agreed sale consideration, cheque payments, and cash component for the transfer of land and machinery. The entries materially matched the subsequent registered sale deed, including the parties, property details, cheque numbers, dates, and amounts. The partner whose handwriting appeared on the document admitted authorship, and the explanation that the paper was only a proposal was found inconsistent with the surrounding circumstances and the final transaction. The document was treated as a speaking and corroborated piece of evidence, not a dumb document. The fact that no physical cash was found during survey did not defeat the addition where the document itself established the existence of unrecorded cash consideration and the assessee failed to rebut the contents satisfactorily.

Conclusion: The addition under section 69A was upheld and the assessee's challenge failed.

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