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Issues: Whether the assessee's explanation regarding the source of the cash found during search was sustainable, and whether any perversity or substantial question of law arose from the concurrent factual findings against him.
Analysis: The explanation that part of the cash belonged to Cain Technology India Pvt. Ltd. was not reflected in the assessee's answer at the time of search, when he stated that the money represented family savings and promised later evidence. The books of account were also not made available during the search. The supporting cashbook material produced later in assessment proceedings was therefore treated as an afterthought. In view of the circumstances recorded by the authorities below, the concurrent findings of fact were not shown to be perverse, and no substantial question of law arose.
Conclusion: The explanation was rejected, and the findings below were upheld in favour of the Revenue.