Section 69A addition fails where sale consideration is proved through banking channels and the transaction is genuine.

An addition under section 69A was held unsustainable where the assessee proved receipt of the full sale consideration through banking channels and established the buyer's identity, the genuineness of the transaction, and the source of funds. The difference between the registered sale value and the actual consideration was attributed to the purchaser's decision to register the deed at the circle rate. In the absence of material showing that the stated consideration exceeded the amount received or represented unaccounted income, the initial burden was treated as discharged and the addition was deleted.

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Issues: Whether the addition made under section 69A of the Income-tax Act, 1961, on account of the difference between the registered sale consideration and the amount claimed to have been actually received from sale of agricultural properties, was sustainable.

Analysis: The assessee produced bank evidence showing receipt of the entire consideration through banking channels and established the identity of the buyer, the genuineness of the sale transaction, and the source of the funds. The difference between the registered value and the alleged actual consideration was attributable to the purchaser's choice to register the deed at the circle rate, and the seller could not compel the purchaser to reflect a different negotiated price. In the absence of any material showing that the stated consideration exceeded the amount received or that the excess arose from unaccounted sources, the initial burden stood discharged.

Conclusion: The addition under section 69A was not sustainable and was deleted, in favour of the assessee.

Ratio Decidendi: Once an assessee substantiates receipt of sale proceeds through banking channels and establishes the identity of the purchaser, the genuineness of the transaction, and the source of funds, an addition under section 69A cannot be sustained merely because the registered deed reflects a lower stamp-value consideration.

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