Unrebutted affidavits and supporting records can defeat an unexplained cash deposit addition when the Revenue offers no contrary evidence.

Where an assessee substantiates a cash deposit with sworn affidavits, land records, bank statement and witness statements showing receipt from the father's claimed agricultural proceeds, jewellery sale and past savings, and the Revenue brings no contrary material, the explanation cannot be rejected on suspicion alone. The unrebutted evidence was accepted, so the addition treating the deposit as unexplained income from undisclosed sources was deleted and the assessment addition was set aside.

---

---

Issues: Whether the cash deposit of Rs. 10,00,000 was rightly treated as unexplained income from undisclosed sources.

Analysis: The assessee claimed that the deposit originated from amounts received from the father, whose source was stated to be agricultural proceeds, sale of jewellery and past savings. The evidentiary record included affidavits, land records, bank statement and supporting statements of witnesses. The Revenue did not bring any contradictory material to rebut these documents. Unrebutted affidavits and supporting evidence could not be discarded on suspicion alone, and the absence of contrary evidence weakened the addition made in assessment.

Conclusion: The addition treating the cash deposit as unexplained income was not sustainable and is deleted.

Final Conclusion: The assessee's explanation for the source of the deposit was accepted, and the assessment addition was set aside.

Ratio Decidendi: Where an assessee substantiates the source of a cash deposit with sworn affidavits and supporting material, and the Revenue fails to rebut that evidence with contrary material, the addition cannot be sustained merely on conjecture or suspicion.

---