Unexplained cash deposits and special-rate taxation fail where business source is supported by bank records and cash flow pattern.

Cash deposits were not sustained as unexplained money under section 69A where the assessee showed that the deposits arose in the course of its potato business and the bank statement supported the stated repayment explanation. On the recorded facts, the source of the cash was consistent with the business pattern, so no addition was warranted. Once the section 69A addition was deleted, the issue of taxation at the special rate under section 115BBE became only consequential and did not affect the result.

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Issues: Whether the addition of cash deposits as unexplained money under section 69A could be sustained, and whether the special rate of tax under section 115BBE was applicable.

Analysis: The assessee explained that the cash deposits were made in the course of its potato business and that the alleged loan repayment explanation could be verified from the bank statement. On the facts recorded, the source of cash deposits was found to be consistent with the assessee's business pattern, and no warrant for addition remained. The ground relating to taxation under section 115BBE did not survive once the addition itself was deleted.

Conclusion: The addition under section 69A was deleted and the assessee succeeded; the special rate issue under section 115BBE became consequential and did not affect the result.

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