Unexplained cash deposits: corroborative evidence and affidavits justified restricting the addition rather than sustaining it in full.

Cash deposits were examined under section 69 as unexplained money, and the assessee supported the explanation with return particulars, land records, affidavits of purchasers, and evidence of sale of cattle, a bullock cart, and agricultural land. The material, together with remand proceedings, showed the deposits broadly matched the available cash flow, although some supporting documents were treated as self-serving and not enough for full deletion. Applying the CBDT verification guidelines for senior citizens as a reference point for scrutiny of cash deposits, the addition was not sustained in full and was restricted to a lump sum of Rs. 2,00,000, with the balance relief allowed.

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Issues: Whether the addition made under section 69 on account of cash deposits as unexplained money was liable to be sustained in full or restricted to a lesser amount.

Analysis: The assessee produced documents to explain the cash deposits, including return details, land records, affidavits of purchasers, and material showing sale of cattle, bullock cart and agricultural land. The explanation was supported by remand proceedings, and the cash deposits were found to broadly tally with the available cash flow. The affidavits and surrounding material were treated as relevant evidence, though some of the supporting documents were regarded as self-serving and not sufficient to full deletion. Reference was also made to the CBDT verification guidelines for senior citizens, under which limited cash deposits may be accepted without further verification, while higher amounts require scrutiny.

Conclusion: The addition was not sustained in full and was restricted to a lump sum amount of Rs. 2,00,000, with the balance relief allowed in favour of the assessee.

Final Conclusion: The assessee succeeded in part, as the impugned addition for unexplained cash deposits was substantially reduced rather than deleted entirely.

Ratio Decidendi: Where the assessee produces credible material and affidavits explaining cash deposits, the addition for unexplained money may be restricted to the extent the explanation remains unsubstantiated, rather than sustained in full.

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