On-money addition fails where seized material does not evidence any actual cash payment and rests only on inference.

On-money addition could not be sustained where the seized material did not show any actual cash payment by the assessee. The ITAT Agra noted that, in proceedings under section 153C read with section 144 of the Income-tax Act, the Assessing Officer's reproduction of the seized documents did not establish the alleged payment; the addition therefore rested on inference rather than proved facts. On that basis, the addition was deleted and the appeal succeeded.

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Issues: Whether the on-money addition of Rs. 8,13,800 could be sustained in the absence of any actual payment reflected in the seized material.

Analysis: The proceedings arose under section 153C read with section 144 of the Income-tax Act, 1961. The seized documents reproduced by the Assessing Officer did not disclose any actual cash payment by the assessee. In the absence of material evidencing such payment, the addition rested only on inference and not on proved facts.

Conclusion: The on-money addition was not sustainable and was deleted.

Final Conclusion: The appeal succeeded and the impugned addition was set aside.

Ratio Decidendi: An income addition cannot be sustained where the seized material does not establish the alleged payment and the conclusion is founded only on inference.

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