Unaccounted cash payment additions require transaction-specific incriminating evidence; estimated on-money assumptions cannot establish actual consideration paid.

An addition for alleged unaccounted cash payment towards purchase of a flat cannot rest on an estimated on-money component without incriminating material proving payment in the assessee's specific transaction. Material and statements obtained during the developer's search did not establish actual unaccounted consideration for the relevant purchase. The Revenue bears the burden of proving income or expenditure actually accrued, received, or incurred; general estimates and presumptions cannot substitute transaction-specific evidence. The notes state that the addition was directed to be deleted in favour of the assessee.

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Issues: Whether addition for alleged unaccounted cash payment towards purchase of a flat could be sustained where it rested on an estimated on-money component without incriminating material evidencing payment by the assessee.

Analysis: The addition arose from material and statements obtained in a search of the developer. The corresponding addition concerning flats in the same project and tower had already been deleted because the alleged on-money was estimated without seized material proving receipt or payment in the particular transactions. The Revenue bears the burden of establishing actual unaccounted consideration; a general estimate or presumption cannot substitute evidence of income or expenditure actually accrued, received, or incurred.

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

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