Section 69A addition needs proof of unaccounted money; a lone diary noting without corroboration is insufficient.

Section 69A cannot be invoked merely from a seized diary notation such as "1.45 cash" unless the Revenue establishes ownership of unaccounted money and links the entry to an actual undisclosed payment or transaction. A solitary, unexplained noting, without proof of cash found in the assessee's possession or corroborative material showing the source or manner of payment, is insufficient to sustain an addition. Where the assessee offers a plausible explanation supported by surrounding facts and the assessment record does not rebut it with evidence, the deletion of the addition is justified and is sustained.

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Issues: Whether addition made under section 69A on the basis of a diary entry noting "1.45 cash" could be sustained without proof of ownership, actual payment, or corroborative material, and whether the deletion of the addition was justified.

Analysis: The impugned addition arose from a seized diary page containing various jottings, including the entry "1.45 cash". The record did not show that cash of Rs. 1.45 crore was actually found in the assessee's possession during search. The assessee explained the noting as a rough fund-planning exercise and supported that explanation with surrounding facts and documents. The assessment order did not bring material on record to establish the manner of payment, source of the alleged cash, or a linkage between the notings and any undisclosed transaction. For application of section 69A, ownership of unaccounted money is a necessary condition, and the provision cannot be invoked on assumptions that the assessee was "available with" the cash or that the noting represented actual payment. A solitary, unexplained noting in a document, without corroboration, cannot by itself justify the addition.

Conclusion: The deletion of the addition was upheld and the Revenue's challenge failed.

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