Unexplained money addition fails where survey receipts are consistently explained as business income and no contrary material is found.

Cash receipts noted in loose papers during survey could not be treated as unexplained money under section 69A where the assessee stated in the section 133A statement that the amounts were business receipts and offered them as additional income. Section 69A applies only when money is found outside the books and the assessee gives no satisfactory explanation as to its nature and source. As the assessee consistently explained the receipts as business income and the Revenue brought no contrary material to show a different source or an untenable explanation, the addition under section 69A was not sustainable and was deleted.

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Issues: Whether the addition of Rs. 2,26,00,000 as unexplained money under section 69A of the Income-tax Act, 1961 was justified when the assessee had admitted during survey that the receipts were business receipts and had offered them as additional business income.

Analysis: The loose papers found during survey showed cash receipts, and in the statement recorded under section 133A, the assessee ed that the receipts were not entered in the books but were income from business and would be offered as additional income. Section 69A applies only where the assessee is found in possession of money not recorded in the books and either offers no explanation about its nature and source or the explanation is found unsatisfactory. Here, the assessee consistently explained the source as business receipts, and the Revenue did not bring any contrary material to show that the money had a different source or that the explanation was untenable.

Conclusion: The addition under section 69A was not sustainable and the deletion of the addition was .

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