Explained: company-owned property, traceable bank trail, and unverified cash deposits limited the unexplained income addition.

Property purchase addition was deleted because the purchase deed and bank trail showed the asset was acquired by a company, so the presence of an individual PAN did not make the consideration taxable in the assessee's hands. Cash deposits in the bank account were not treated as wholly unexplained because the lower authorities had not properly verified related withdrawals or made specific findings; the addition was restricted to Rs. 3.5 lakhs. Credit card payment addition was also deleted because it was linked to the same banking trail and the restricted cash deposit was treated as the source.

---

---

Issues: (i) whether the addition made towards the property purchase was sustainable when the property stood in the name of a company and not in the assessee's individual name; (ii) whether the cash deposits in the bank account were liable to be added in full as unexplained income; and (iii) whether the addition made towards credit card payments could survive independently.

Issue (i): whether the addition made towards the property purchase was sustainable when the property stood in the name of a company and not in the assessee's individual name.

Analysis: The purchase deed showed that the property had been acquired by M/s. Nagarka Property and Finance Private Limited through its director, and the bank records supported the payments made to the seller by the company. The PAN of the natural person appearing in the deed did not alter the fact that the property was purchased in the name of a legal person.

Conclusion: The addition towards the property purchase was deleted and decided in favour of the assessee.

Issue (ii): whether the cash deposits in the bank account were liable to be added in full as unexplained income.

Analysis: The bank statement showed cash deposits described as cash deposit @ Dwarka, but the lower authorities had not properly verified the related withdrawals or given a specific finding on the entries. In view of the surrounding facts and the limited material on record, the full addition was not sustained.

Conclusion: The cash deposit addition was restricted to Rs. 3.5 lakhs and the assessee was granted partial relief.

Issue (iii): whether the addition made towards credit card payments could survive independently.

Analysis: The credit card payment was linked to the same banking trail and the restricted cash deposit addition was treated as the source for the payment.

Conclusion: The addition towards credit card payments was deleted and decided in favour of the assessee.

Final Conclusion: The appeal succeeded in part, with the property-related addition and the credit card addition deleted and the cash-deposit addition reduced substantially.

Ratio Decidendi: Where the surrounding documentary evidence shows that an asset or payment belongs to a different legal person or that the source of a transaction is reasonably traceable, an addition for unexplained income cannot be sustained in full without proper verification and specific findings.

---