Section 69A addition on alleged on-money receipts failed where the Tribunal accepted the factual explanation and no substantial question of law arose.

Deletion of an addition under section 69A was upheld where the alleged on-money receipts from flat sales rested on a single impounded letter and an unsupported assumption that the same differential amount applied to all sales. The Tribunal accepted the taxpayer's factual explanation that the first booking was cancelled, the token amount was refunded, and the flat was later sold to another purchaser at a lower agreed price, supported by affidavit and payment details. The High Court found the revenue authorities' approach conjectural, with no perversity or incorrect application of legal principles in the Tribunal's appreciation of evidence, and held that no substantial question of law arose.

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Issues: Whether the deletion of the addition made under section 69A, based on alleged on-money receipts from flat sales and electronic evidence, gave rise to any substantial question of law.

Analysis: The addition rested on a single impounded letter and a corresponding assumption that the same differential amount applied to all other flat sales. No further enquiry was made to verify the alleged undisclosed receipts. The explanation that the first booking was cancelled, the token amount was refunded, and the flat was later sold to another purchaser at a lower agreed price was accepted on the facts, supported by affidavit and payment details. The reasoning of the Assessing Officer and the first appellate authority was treated as conjectural, and no perversity or incorrect application of legal principles in the Tribunal's appreciation of the evidence was found.

Conclusion: The deletion of the addition was upheld and no substantial question of law arose.

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