Unexplained cash deposits under section 69A fail where sale deed and bank records substantiate the source of funds.

Cash deposits in a bank account were not liable to be treated as unexplained money under section 69A where the assessee supported the source with a registered sale deed and bank records. The documentary evidence showed a share in sold agricultural land, receipt of part consideration by cheque and the balance in cash, and deposits made proximate to the sale transaction. Earlier cash withdrawals were partly accepted by the Assessing Officer, and the remaining source was found plausible on the record. The addition for unexplained cash deposits was deleted.

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Issues: Whether the addition sustained under section 69A for cash deposits in the bank account was justified when the assessee claimed that the deposits represented sale proceeds of agricultural land and earlier cash withdrawals.

Analysis: The assessee produced the registered sale deed and bank statement. The evidence showed that the assessee had a share in the agricultural land sold, that part of the consideration was received by cheque and the balance in cash, and that the cash deposits in the bank were made on dates proximate to the sale transaction. The explanation regarding earlier cash withdrawals had already been accepted to a limited extent by the Assessing Officer, and the remaining source was found to be plausible on the basis of the documentary record and the timing of deposits.

Conclusion: The addition for unexplained cash deposits was not sustainable and was deleted in favour of the assessee.

Final Conclusion: The assessee's explanation for the cash deposits was accepted as satisfactorily supported by the sale deed and bank records, so the assessed addition did not survive.

Ratio Decidendi: Where cash deposits are supported by contemporaneous documentary evidence showing receipt of sale consideration and proximate banking entries, the explanation cannot be rejected as unexplained money under section 69A.

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