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Issues: Whether the addition of Rs. 5,00,000 as unexplained investment on account of an alleged cash payment for purchase of shops was sustainable.
Analysis: The addition was made on the basis of material found during search and an Excel sheet said to record cash payments, together with statements of persons associated with the searched group. However, the assessee denied any cash payment during the relevant assessment year and relied upon the registered purchase documents and a confirmation letter from the seller stating that no cash was received from the assessee and that the shops were sold in the subsequent year through banking channels. No independent corroborative evidence was brought on record to substantiate the alleged cash transaction. In these circumstances, the presumption drawn by the Assessing Officer was found to be unsupported by reliable material.
Conclusion: The addition under section 69 was unsustainable and was deleted; the issue was decided in favour of the assessee.
Ratio Decidendi: An addition for unexplained investment cannot rest solely on uncorroborated third-party material or presumptive inference when the assessee's denial is supported by documentary evidence and the revenue fails to establish the alleged cash payment with independent proof.
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