Unaccounted foreign currency addition sustained where the assessee failed to prove a reliable source for cash found during search.

Foreign currency found during search was treated as unaccounted income because the explanation that it represented foreign-travel leftovers was not supported by reliable evidence. The invoices produced related to different years and did not match the currencies and denominations actually found, so the assessee failed to discharge the onus to explain the source of the cash. The addition was therefore upheld.

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Issues: Whether the addition made on account of foreign currency found during search as unaccounted income was liable to be deleted.

Analysis: Foreign currency was found during search from the relevant premises, and the explanation that it represented leftovers from foreign travel was not supported by reliable evidence. The invoices produced related to different years and did not match the currencies actually found, which included denominations not covered by the documents relied upon. The assessee therefore failed to discharge the onus to explain the source of the currency.

Conclusion: The addition was upheld and the assessee's challenge failed.

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