Unexplained-income additions need a clear nexus and corroborative proof; third-party seized material alone cannot sustain on-money allegations.

Unexplained-income additions based on seized third-party documents require a demonstrable nexus between the material and the assessee, along with corroborative evidence of actual payment. A seized Excel sheet that did not identify the assessee, the property, or any direct cash trail, and statements of sellers unaccompanied by independent proof, were insufficient to support an addition under section 69 read with section 115BBE. Suspicion alone and material found at third-party premises could not discharge the Revenue's burden. The appellate deletion of the alleged on-money addition was upheld.

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Issues: Whether the alleged on-money payment for purchase of immovable property could be added as unexplained income under section 69 of the Income-tax Act, 1961, read with section 115BBE, on the basis of a seized Excel sheet and statements of the sellers.

Analysis: The seized Excel sheet did not contain the assessee's name, the property details, or any direct link showing payment by the assessee. The material was found from the premises of third parties, and no incriminating material was seized from the assessee. The Revenue also did not bring any independent corroborative evidence to establish the nexus between the document and the assessee or to prove actual transfer of cash. The addition was therefore founded only on suspicion and on third-party material, without discharge of the burden to prove the alleged consideration.

Conclusion: The addition of Rs. 3,80,05,000/- was not sustainable and the deletion made by the appellate authority was upheld.

Final Conclusion: The Revenue's appeal failed because the alleged on-money payment was not proved by reliable evidence linking the assessee to the seized material.

Ratio Decidendi: Unexplained-income additions based on seized third-party documents require a demonstrable nexus with the assessee and corroborative evidence; suspicion, without proof of actual payment, cannot sustain the addition.

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