Cash deposit addition cannot stand when supporting evidence remains unrebutted and source explanations are documented.

Cash deposit additions in the assessee's bank account were unsustainable where the assessee produced a cash summary and supporting documentary evidence, including material explaining gifts from the father and business receipts. The evidentiary record was not shown to be defective or unreliable, and the appellate authority did not discredit the documents or explain why the evidence was unacceptable. In the absence of any effective rebuttal, an addition cannot be maintained on suspicion or surmise. The ITAT Surat deleted the addition sustained by the appellate authority.

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Issues: Whether the addition made on account of cash deposits in the assessee's bank account was sustainable when the assessee produced supporting cash summary and documentary evidence before the appellate authorities.

Analysis: The assessee furnished an explanation for the cash deposits, including evidence of gift from the father and business receipts, and the material placed on record was not shown to be defective or unreliable. The appellate authority had sustained part of the addition without discrediting the supporting documents or indicating why the evidence was unacceptable. When the evidentiary support for the source of deposits remains unrefuted, the addition cannot be sustained on mere suspicion or surmise.

Conclusion: The addition sustained by the appellate authority was deleted and the cash deposit addition was held unsustainable.

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