Unexplained cash deposits and agricultural land sale evidence required fresh verification; matter remanded for de novo adjudication.

Cash deposits in the assessee's bank account were alleged to be unexplained income, but the explanation that they represented sale consideration from agricultural land required proper verification of the unregistered sale agreements, affidavit, witnesses and surrounding circumstances. The record showed that these materials had not been independently examined and the source of the deposits was not conclusively established merely by relying on the lesser consideration in the registered sale deed. The matter was therefore remanded to the first appellate authority for de novo adjudication after giving the assessee a proper opportunity to substantiate the cash deposits and for fresh fact-finding on the evidentiary value of the sale-related material.

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Issues: Whether the addition treating cash deposits in the assessee's bank account as unexplained income could be sustained without proper verification of the unregistered sale agreements and supporting evidence regarding the sale of agricultural land.

Analysis: The assessee's explanation was that he was an agriculturist with no other source of income and that the cash deposits represented sale consideration received from agricultural land. The addition had been confirmed primarily on the basis that the registered sale deed reflected a lesser consideration and that oral or unregistered material could not contradict the written instrument. The appellate record showed that the unregistered agreements, affidavit, and surrounding circumstances had not been independently verified, and the purchaser, witnesses, and local market value were not adequately examined. In these circumstances, the proper course was fresh fact-finding with verification of the additional material and a reasoned reconsideration of the source of the deposits.

Conclusion: The addition was not finally sustained on the existing record and the matter was remanded to the first appellate authority for de novo adjudication after giving the assessee a proper opportunity to substantiate the source of the cash deposits.

Final Conclusion: The dispute was restored for fresh consideration so that the evidentiary value of the sale-related material and the explanation for the bank deposits could be examined on merits.

Ratio Decidendi: Where material evidence bearing on the source of bank deposits has not been properly verified, the matter should be reconsidered afresh in accordance with natural justice rather than being concluded solely on the face of the registered sale deed.

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