Section 69A addition sustained on independent evidence linking cash to the assessee, despite challenge to police statement.

Addition under section 69A was supported by material linking the cash to the assessee, not by the police statement under section 161 alone. The sworn statement of the angadia firm's partner, the transaction receipt, and surrounding circumstances, including the misappropriation complaint, provided independent evidentiary support that the cash belonged to the assessee. The dispute was treated as one of evidence appreciation rather than a substantial question of law, and the addition was upheld.

---

---

Issues: Whether the addition made under section 69A of the Income-tax Act, 1961, could be sustained on the basis of the materials linking the cash amount to the assessee, notwithstanding the assessee's challenge to the police statement recorded under section 161 of the Code of Criminal Procedure, 1973.

Analysis: The statement recorded by the police under section 161 of the Code of Criminal Procedure, 1973, was not the sole basis of the addition. Independent material included the sworn statement of the partner of the angadia firm, who stated that the cash had been handed over by the assessee for delivery, and the production of one of the receipts issued for the transaction. The surrounding circumstances, including the police complaint arising from the alleged misappropriation of the cash in transit, supported the conclusion that the amount belonged to the assessee. The controversy turned on evidence and its appreciation, and did not raise any substantial question of law.

Conclusion: The addition under section 69A was upheld and the appeal was dismissed.

---