Unexplained cash deposits remitted for fresh verification after Tribunal granted one final opportunity to prove the source.

Cash deposits in the assessee's bank account were treated as unexplained income because the explanation of opening cash in hand, sale proceeds of closing stock, and realisation from debtors was not supported by primary or corroborative evidence. The Tribunal did not finally sustain or delete the addition; instead, it restored the matter to the Assessing Officer for fresh verification, holding that the assessee should be given one final opportunity to substantiate the source of the deposits with evidence. The issue was remitted for a fresh decision in the interest of justice.

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Issues: Whether the addition made on account of cash deposits in the bank account as unexplained income was liable to be sustained or the matter required fresh examination.

Analysis: The addition arose from cash deposits in the assessee's bank account, which the assessee claimed were sourced from opening cash in hand, sale proceeds of closing stock, and realization from debtors. The authorities below rejected the explanation for want of primary and corroborative evidence, and treated the balance deposit as unexplained cash credit. In appellate proceedings before the Tribunal, the assessee sought one final opportunity to substantiate the source of the deposits. Considering the overall facts and the interest of justice, the Tribunal found it appropriate to restore the matter to the Assessing Officer for fresh verification and to afford the assessee an opportunity to support its claim with evidence.

Conclusion: The addition was not finally sustained or deleted and the issue was remitted to the Assessing Officer for fresh decision after granting one final opportunity to the assessee.

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