Unexplained cash addition upheld where property-purchase explanation lacked credibility and failed to satisfy the initial onus.

Cash found in the assessee's possession was treated as unexplained income because the explanation that seventeen persons had contributed the money for a proposed property purchase was found inconsistent with ordinary conduct and the surrounding seizure circumstances. The tribunal held that the initial onus was not discharged by a plausible or probable explanation, and further enquiry by summoning the alleged contributors under section 131 was unnecessary on these facts. Applying the presumption principle reflected in section 114 of the Indian Evidence Act, the addition under section 69A was upheld.

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Issues: Whether the addition of cash as unexplained income was sustainable when the assessee claimed that the amount was collected from relatives and associates for purchase of property.

Analysis: The explanation that seventeen persons contributed substantial cash for a proposed property purchase, and that the amount was being transported back after the deal failed, was found inconsistent with ordinary human conduct and the surrounding circumstances of the seizure. The Court noted that although the Assessing Officer did not summon the contributors under section 131, such further enquiry was not required because the assessee's explanation itself did not satisfactorily discharge the initial onus. The presumption principle reflected in section 114 of the Indian Evidence Act was applied to assess the plausibility of the explanation, and the Court found the narrative lacked the degree of probability needed to reject the addition.

Conclusion: The addition under section 69A was upheld and the assessee's challenge failed.

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