Cash deposits backed by customer confirmations and sale deeds were not unexplained credits under section 68.

Cash deposits linked to flat bookings were not liable to be treated as unexplained income under section 68 where the assessee produced customer confirmations, PAN details, bank particulars and registered sale deeds showing that the receipts were advances from multiple purchasers. The documentary trail traced the cash to property transactions, and the Revenue did not bring effective rebuttal or contrary enquiry to dislodge that evidence. On those facts, the source of the deposits stood explained and the section 68 addition was deleted, granting partial relief to the assessee.

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Issues: Whether cash deposits of Rs. 19 lakhs were liable to be added as unexplained income under section 68 of the Income-tax Act, 1961, or whether the assessee had satisfactorily explained the source as advances received from customers for booking and sale of flats.

Analysis: The assessee produced customer confirmations, PAN details, bank particulars, and registered sale deeds showing that the impugned cash receipts formed part of flat transactions. The receipts were traced to multiple purchasers, and the sale deeds recorded payments in cash as well as through banking channels. No contrary enquiry or effective rebuttal was made by the Revenue to dislodge the documentary material. On these facts, the source of the cash deposits stood explained as advance receipts from customers towards flat sales rather than unexplained income.

Conclusion: The addition under section 68 was not justified and was deleted, thereby allowing the assessee's substantive grounds.

Final Conclusion: The assessment was interfered with only to the extent of the cash-deposit addition, resulting in partial relief to the assessee.

Ratio Decidendi: Where cash deposits are supported by contemporaneous customer confirmations and registered sale deeds evidencing advances toward property transactions, and the Revenue does not effectively rebut that evidence, the deposits cannot be treated as unexplained credits under section 68.

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