Unexplained cash credits sustained where source, capacity, and supporting evidence for deposits were not proved.

Cash deposits explained as receipts from a husband and son, and as past savings from dairy and livestock activity, were sustained as unexplained because the assessee did not produce credible evidence of source, capacity, or surrounding circumstances. The claimed plot-sale proceeds were not fully supported by the purchaser's statement, and the husband could not explain the balance source; the son's salary and alleged labour income did not substantiate the deposit; and the asserted accumulated savings lacked reliable particulars of accumulation and retention. The ITAT Delhi upheld the additions, finding that the burden to prove the nature and source of the credits had not been discharged.

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Issues: (i) Whether the addition sustained on account of cash deposit of Rs. 2,00,000 claimed to have been received from the assessee's husband was justified; (ii) Whether the addition sustained on account of cash deposit of Rs. 1,37,000 claimed to have been received from the assessee's son was justified; (iii) Whether the addition sustained on account of cash deposit of Rs. 6,00,000 against claimed past savings from dairy and livestock activity was justified.

Issue (i): Whether the addition sustained on account of cash deposit of Rs. 2,00,000 claimed to have been received from the assessee's husband was justified.

Analysis: The explanation that the amount was sourced from sale proceeds of a plot was not accepted because the purchaser's statement showed that only part of the consideration had actually been paid at the relevant time, and the assessee's husband could not explain the source of the balance. The assessee failed to establish the source and creditworthiness supporting the claim.

Conclusion: The addition of Rs. 2,00,000 was rightly sustained, against the assessee.

Issue (ii): Whether the addition sustained on account of cash deposit of Rs. 1,37,000 claimed to have been received from the assessee's son was justified.

Analysis: The son's salary income for the relevant period did not support the amount claimed, and the further explanation based on occasional labour work remained unquantified and unproved. The assessee did not discharge the burden of proving the source of the deposit.

Conclusion: The addition of Rs. 1,37,000 was rightly sustained, against the assessee.

Issue (iii): Whether the addition sustained on account of cash deposit of Rs. 6,00,000 against claimed past savings from dairy and livestock activity was justified.

Analysis: The explanation of accumulated cash savings was found unsupported by reliable particulars such as the period of accumulation, sale of livestock, or credible retention of such large cash at home. The explanation was accepted only to a limited extent, and the estimate of available savings was upheld as reasonable.

Conclusion: The addition of Rs. 6,00,000 was rightly sustained, against the assessee.

Final Conclusion: The Tribunal upheld the additions made by the lower authorities and found no merit in the assessee's challenge to the assessment.

Ratio Decidendi: Where cash credits or bank deposits are explained by the assessee, the explanation must be supported by credible evidence of source, capacity, and surrounding circumstances; failing this, the addition as unexplained income can be sustained.

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