Uncorroborated on-money allegation in land purchase fails where registered sale deeds and records support the stated consideration.

An addition for alleged on-money in the purchase of agricultural land cannot be sustained on uncorroborated statements alone when no documentary evidence shows payment beyond the registered sale consideration. The registered sale deeds reflected the stated value and matched the sub-registrar's valuation, while the Revenue failed to produce reliable contrary material to displace the presumption of genuineness attaching to the deeds. The addition was therefore deleted in favour of the assessee.

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Issues: Whether the addition made on the basis of alleged cash payment over and above the registered consideration for purchase of agricultural land was sustainable.

Analysis: The addition was based on statements of the seller's legal heirs and one witness, but there was no documentary material showing payment of any amount beyond the consideration stated in the registered sale deeds. The registered value matched the sub-registrar's valuation noted in the deeds. The material relied upon by the Revenue remained uncorroborated, and the evidentiary basis was found inadequate. A registered sale deed carries a presumption of genuineness, and the Revenue did not produce reliable contrary evidence to displace it.

Conclusion: The addition was unsustainable and was deleted. The issue is decided in favour of the assessee.

Ratio Decidendi: An addition for alleged on-money in a land transaction cannot be sustained merely on uncorroborated statements when the registered sale deed and surrounding records do not support payment over and above the stated consideration.

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