Reassessment sanction and unexplained money addition were upheld where registered sale evidence and burden of proof defeated the taxpayer's challenge.

Reassessment was upheld because sanction under section 151 was based on the Assessing Officer's recorded reasons, and separate de hors satisfaction by the approving authority was not required; the challenge that approval was mechanical failed. The addition as unexplained money under section 69A was also sustained because the assessee could not prove that cash deposits came from agricultural land sale proceeds, the registered sale deed showed a lower consideration, and purchasers' statements supported the deed. The Tribunal accepted that a registered document cannot be contradicted by contrary oral evidence and that the burden remained on the assessee for facts within his knowledge.

---

---

Issues: (i) Whether the reassessment proceedings were invalid for want of proper sanction under section 151 of the Income-tax Act, 1961. (ii) Whether the addition made as unexplained money under section 69A of the Income-tax Act, 1961 was sustainable.

Issue (i): Whether the reassessment proceedings were invalid for want of proper sanction under section 151 of the Income-tax Act, 1961.

Analysis: The reassessment was initiated on the basis of information that the assessee had made cash deposits in the bank account. The sanction granted by the competent authority was examined in the light of the reasons recorded by the Assessing Officer. The approval under section 151 was held to be valid because the competent authority's satisfaction was based on the reasons recorded by the Assessing Officer, and independent satisfaction de hors those reasons was not required. The challenge that the approval was mechanical and without application of mind was rejected.

Conclusion: The reassessment proceedings were held to be valid and the challenge to the notice and consequent assessment failed.

Issue (ii): Whether the addition made as unexplained money under section 69A of the Income-tax Act, 1961 was sustainable.

Analysis: The assessee claimed that the cash deposits came from sale proceeds of agricultural land. The Tribunal found that the registered sale deed reflected a much lower sale consideration and there was no reliable documentary basis for the higher amount asserted by the assessee. The purchasers' statements corroborated the registered deed. The Tribunal also relied on the rule that written terms in a registered document cannot be contradicted by contrary oral evidence, and that the burden lay on the assessee to prove facts especially within his knowledge. The plea based on lack of cross-examination and unrebutted affidavits did not displace the documentary evidence on record.

Conclusion: The addition as unexplained money was sustained and the assessee's challenge was rejected.

Final Conclusion: The appeal was dismissed in full and the orders of the lower authorities were sustained.

---