Unexplained money treatment rejected for bank withdrawals made under a proved agency arrangement with explained credits.

Bank withdrawals made in the course of a proved agency arrangement were not assessable as unexplained money under section 69A of the Income-tax Act, 1961, where the assessee showed that it acted as a Customer Service Point agent and the credits in the bank account were supported by contemporaneous records. The appellate authority's factual findings accepted that the amounts were handled for customers through the agency arrangement and that the source of the credits was explained, while the small commission earned on the transactions had already been offered to tax. On that basis, the additions on account of bank withdrawals and contractual receipts were not sustainable, and the Revenue's appeal was dismissed.

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Issues: Whether the additions made on account of bank withdrawals and contractual receipts were sustainable, and whether admission of additional evidence by the first appellate authority without a remand report vitiated the relief granted.

Analysis: The assessee was found to be acting as a Customer Service Point agent on behalf of a bank through Save Solutions Pvt. Ltd., and the credits in the bank account were supported by the contemporaneous records placed before the first appellate authority. The withdrawals represented amounts handled for customers in the course of that agency arrangement, and the source of the credits was not shown to be unexplained. In these circumstances, the withdrawal of money from the bank account could not be treated as unexplained money under section 69A of the Income-tax Act, 1961. The appellate authority's factual findings also showed that the small commission earned on the transactions had been offered to tax.

Conclusion: The additions were not sustainable, and the Revenue's appeal was dismissed.

Ratio Decidendi: Bank withdrawals made in the course of a proved agency arrangement, where the source of credits is explained and not disputed, cannot be assessed as unexplained money under section 69A of the Income-tax Act, 1961.

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