Unexplained money addition requires proof linking the assessee to an alleged receipt; unsupported addition was deleted.

An addition for unexplained money under Section 69A requires a factual foundation linking the assessee to the alleged receipt. The Assessing Officer did not identify the date of the purported transaction or produce material establishing any transaction with the alleged payer. The assessee's bank statement showed no receipt from that entity, but this evidence was ignored. As the initial burden to establish the nature and occurrence of the alleged transaction was not discharged, deletion of the addition was sustained in favour of the assessee.

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Issues: Whether the addition for unexplained money could be sustained where the Assessing Officer did not establish any transaction between the assessee and the alleged payer.

Analysis: An addition under Section 69A required a factual foundation linking the assessee to the alleged receipt. The Assessing Officer neither identified the date of the purported transaction nor produced material establishing a transaction with the alleged payer. The assessee's bank statement showed no receipt from that entity, and the assessment ignored this evidence. The initial burden to establish the nature and occurrence of the alleged transaction was not discharged.

Conclusion: The deletion of the addition was sustained in favour of the assessee.

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