Unexplained investment addition fails where alleged flat on-money rests on estimation without evidence of actual cash payment.

Addition for unexplained investment under Section 69 based on alleged cash on-money payment for a residential flat was unsustainable where the allegation for the relevant tower rested solely on estimated sale rates. The related developer's additions based on estimates without supporting seized material had been deleted, and no evidence established actual cash payment beyond the documented purchase price. The addition was therefore directed to be deleted.

---

---

Issues: Whether addition for unexplained investment based on alleged cash on-money paid towards purchase of a residential flat could be sustained where the underlying on-money allegation for the relevant tower was estimated without incriminating material.

Analysis: The addition concerning the relevant residential unit arose from an estimated on-money component. In the related developer's case, additions based on estimated sale rates for flats without supporting seized material had been deleted. The record established that the allegation concerning Tower 8 was similarly founded on estimation rather than evidence of actual cash payment. The Revenue did not establish the alleged consideration beyond the documented purchase price.

Conclusion: The addition under Section 69 for alleged on-money payment was unsustainable and was directed to be deleted, in favour of the assessee.

---