Unaccounted investment addition under section 69A failed where the same cash investment was already taxed in company hands.

Additions for alleged unaccounted investment under section 69A were unsustainable where seized entries stood in the assessee's name but the surrounding documents and related assessments showed the actual investments were made by three companies. The evidence did not establish that the assessee himself had made the investment, and the same cash investment had already been taxed in the companies' hands. On those facts, the proposed addition would have duplicated the same amount in the assessee's assessment, so deletion of the addition was upheld and the Revenue's challenge failed.

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Issues: Whether the addition made towards alleged unaccounted investment was sustainable in the hands of the assessee under section 69A of the Income-tax Act, 1961.

Analysis: The seized material showed investment entries against the assessee's name, but the surrounding documents and related assessments indicated that the actual investments were made by three companies. The same cash investment had already been brought to tax in those companies' hands, and the evidence did not establish that the assessee himself had made the investment. On the facts found, the addition in the assessee's hands amounted to duplication of the same amount.

Conclusion: The deletion of the addition was upheld and the revenue's challenge failed.

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