Burden of proof for cash deposits and deduction claims sustains additions when the assessee files no return or evidence.

Where an assessee failed to file the return of income despite notices and did not substantiate cash deposits, section 80P deduction, or expense claims with supporting evidence, the additions and disallowances were sustained on the material available. The record showed continued non-compliance with statutory notices under sections 142(1) and 144, and no satisfactory explanation or documentary proof was furnished before the Assessing Officer or in appeal. In such circumstances, the burden of proving the source of deposits and entitlement to deductions remained undischarged, so the appellate order sustaining the additions was upheld.

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Issues: Whether the additions made on account of cash deposits, denial of deduction under section 80P, and disallowance of expenses were liable to be deleted when the assessee did not file the return of income and failed to substantiate the source of deposits with evidence.

Analysis: The assessee society was required to file a return for the relevant assessment year but did not do so despite notices under section 142(1) and section 144. No satisfactory explanation or documentary support was furnished either before the Assessing Officer or in appellate proceedings to explain the cash deposits in the bank account. In the absence of a return and supporting material, the additions were made on the basis of the material available and the first appellate authority sustained them. The record disclosed continued non-compliance and failure to discharge the burden of proving the source of the cash deposits or the entitlement to the claimed deductions and expenses.

Conclusion: The additions and related disallowances were rightly sustained and were not liable to be deleted.

Final Conclusion: The assessee failed to establish any infirmity in the appellate order, and the Revenue's stand on the sustained additions prevailed.

Ratio Decidendi: Where an assessee fails to file the return of income and does not substantiate cash deposits or claimed deductions with evidence despite statutory notices, the authorities may sustain the additions and disallowances on the material available.

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