Double addition barred where unexplained receipts already taxed cannot be added again as investment out of the same income.

Unexplained receipts taxed under section 68 could not be subjected to a second addition merely because the same funds were later invested. The Tribunal noted that once the Assessing Officer had already treated the receipts as income from unexplained sources, any subsequent investment made out of those receipts was only an application of the same income. The Commissioner (Appeals) therefore correctly sustained the addition for the unexplained receipts but deleted the further addition relating to their deployment in investments, since the same amount could not be assessed twice. The deletion of the second addition was upheld and the Revenue's challenge failed.

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Issues: Whether the addition made on account of unexplained receipts under Section 68 of the Income-tax Act, 1961 could again be made in respect of investments said to have been made out of the same receipts, resulting in double addition.

Analysis: The Tribunal noted that the Assessing Officer had already brought the impugned receipts to tax as unexplained sources. Once the same amount was treated as income, any subsequent deployment of that amount into investments represented only an application of the same income. On that basis, the Commissioner (Appeals) rightly sustained the addition relating to unexplained receipts but deleted the further addition made towards application of those very receipts in investments, since the same amount could not be assessed twice.

Conclusion: The deletion of the second addition was upheld and the Revenue's challenge failed.

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