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Issues: (i) Whether the addition of an alleged unexplained bank credit of Rs. 2.46 crore could be sustained on the existing material, or whether the matter required fresh examination in view of conflicting bank statements and absence of reconciliation.
Issue (i): Whether the addition of an alleged unexplained bank credit of Rs. 2.46 crore could be sustained on the existing material, or whether the matter required fresh examination in view of conflicting bank statements and absence of reconciliation.
Analysis: The disputed credit appeared in one bank statement for the relevant account and date, while another statement produced by the assessee did not show the entry and reflected a different closing balance. The assessee relied on entries in later periods and on its books, whereas the Revenue relied on the bank-generated statement forming part of the assessment record. The matter was not reconciled with the concerned bank authorities, and the basis for the credit entry on the disputed date was not satisfactorily established on the existing record.
Conclusion: The deletion of the addition was set aside and the issue was remanded for fresh adjudication after proper reconciliation and opportunity to both sides.
Final Conclusion: The disputed addition was not finally deleted on the existing record, and the matter was sent back for reconsideration in accordance with law.
Ratio Decidendi: Where material bank entries are disputed and the accounts are not reconciled, a deletion of addition cannot stand without a fair and complete verification of the underlying records.
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