Cash redeposit from past savings was not treated as unexplained income under section 69A.

A cash redeposit in a savings bank account was held not to be unexplained money under section 69A where the assessee explained it as redeployment of own accumulated savings earlier withdrawn for family and medical needs during the demonetisation period. The explanation was not disproved by the Revenue, and the fact that presumptive taxation had already been applied to deposits in a separate current account did not change the character of the savings account deposit. On the record, mere redeposit of cash was insufficient to establish unexplained income, so the addition was not sustainable.

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Issues: Whether the cash deposit of Rs. 2,50,000 in the savings bank account could be treated as unexplained money under section 69A of the Income-tax Act, 1961.

Analysis: The deposit was explained as part of the assessee's own accumulated savings, earlier withdrawn for family and medical needs and redeposited during the demonetisation period. The explanation was not disproved by the Revenue. The fact that the assessee had already been subjected to presumptive taxation on the current account deposits did not alter the distinct character of the savings bank deposit. On the record, the redeposit of cash by itself did not establish that the amount represented unexplained income.

Conclusion: The addition under section 69A of the Income-tax Act, 1961 was not sustainable and the deposit of Rs. 2,50,000 was held to be the assessee's own past savings.

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