Explained cash receipts and documentary support defeated an unexplained-money addition where the remand report accepted genuineness.

Cash found during search was treated as explained where the assessee supported the receipt with a registered joint development agreement, linked the balance to later receipts and agricultural income, and the remand report did not dispute the genuineness of the receipt. The Tribunal noted that further enquiry, including examination of the alleged payors, was necessary before rejecting the explanation. In the absence of contrary evidence, documentary support and the remand report were sufficient to displace an unexplained-money addition, and the addition under section 69A was not sustainable.

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Issues: Whether the cash found during search could be sustained as unexplained money under section 69A, or whether the assessee had satisfactorily explained the source of the cash through the joint development agreement and other supporting material.

Analysis: The assessee showed that a part of the cash was received under a registered joint development agreement and the remaining amount was linked to subsequent receipts and agricultural income. The Assessing Officer's remand report did not dispute the genuineness of the cash receipt under the agreement. The Tribunal held that the Commissioner (Appeals) should have made further enquiry, including with the persons said to have paid the cash, before rejecting the explanation. In the absence of contrary evidence, the explanation supported by the remand report and documentary material could not be disregarded merely because the cash was found much later during search.

Conclusion: The assessee had satisfactorily explained the source of the cash, and the addition under section 69A was not sustainable.

Ratio Decidendi: Where the assessee substantiates the source of cash with documentary evidence and the remand report accepts the genuineness of the receipt, an unexplained-money addition cannot be sustained without further contrary enquiry or evidence.

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