Custodianship of Sale Proceeds: contemporaneous deeds and bank records negated beneficial ownership, so deposits not taxed as unexplained income.

Cash deposits contemporaneous with registered sale deeds were held to be custodial receipts of agricultural land sale proceeds where documentary sale deeds, matching bank statements, absence of beneficial gain, and subsequent transfers to sellers showed no beneficial ownership by the depositor; consequence: deposits were not taxable as unexplained income under the deeming provisions and additions were deleted. Smaller contemporaneous deposits supported by jamabandi and the family's sole agricultural income were accepted as agricultural receipts, with corresponding additions deleted and the appeal allowed on merits.

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Issues: (i) Whether the cash deposits of Rs. 61,50,000/- made on 19.05.2014 in the assessee's bank account are taxable as unexplained income under the deeming provisions of Section 69A read with Section 115BBE of the Income-tax Act, 1961 or whether they represent funds held by the assessee as a custodian for sale proceeds of agricultural land; (ii) Whether cash deposits of Rs. 2,52,000/- in April-May 2014 are explained as agricultural receipts of the assessee.

Issue (i): Whether the Rs. 61,50,000/- deposit is the assessee's income or custody of sale proceeds of agricultural lands sold by family members.

Analysis: The deposit date coincides with registration of sale deeds dated 19.05.2014. Documentary record includes registered sale deeds, contemporaneous bank statements showing deposits into the assessee's and another custodian's accounts on the same date, and subsequent bank transfers from the assessee to the sellers on 19.02.2016. The assessee and extended family are agriculturists with no other income-earning activities. The first appellate authority admitted the additional evidence under Rule 46A of the Income-tax Rules, 1962 and there were no adverse comments from the assessing officer. The tribunal evaluated whether the assessee derived benefit or was the beneficial owner of the funds by examining duration of custody, lack of any gain, and ultimate utilisation by the sellers.

Conclusion: The Rs. 61,50,000/- deposit is held by the assessee as a custodian of sale proceeds and not the assessee's taxable income; the addition under Section 69A read with Section 115BBE is deleted in favour of the assessee.

Issue (ii): Whether the aggregate Rs. 2,52,000/- deposited in April-May 2014 is explained as agricultural receipts.

Analysis: The assessee produced jamabandi evidencing agricultural holdings of his parents and explained that these smaller deposits arose from agricultural activity. No contrary material was placed on record to dispute that the family's sole income source was agriculture.

Conclusion: The Rs. 2,52,000/- deposits are accepted as agricultural receipts and the addition is deleted in favour of the assessee.

Final Conclusion: The appeal is allowed on merits by deleting the additions of Rs. 61,50,000/- and Rs. 2,52,000/-, resulting in a decision favourable to the assessee and disposing of the appeal against the assessment order.

Ratio Decidendi: Contemporaneous deposit matching registered sale deeds together with documentary evidence of custody, absence of beneficial gain, and subsequent transfer to sellers establishes custodianship of sale proceeds and negates treatment of such deposits as unexplained income under Section 69A read with Section 115BBE of the Income-tax Act, 1961.

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