Documentary evidence and unrebutted books defeat additions for unexplained money, investment and capital gains computation.

Cash deposits supported by a cash book, monthly cash summary and brokerage income explanation could not be treated as unexplained money under section 69A, because the books were not validly rejected and no contrary material showed another source. Property investment was also accepted as explained under section 69, since loan confirmations, banking entries and evidence of lender creditworthiness supported the purchase and no rebuttal evidence was produced. The assessee's short-term capital gain computation was upheld on the basis of the purchase deed and consent agreement, as the record supported the worked-out cost and share and the Revenue failed to substantiate a higher addition.

---

---

Issues: (i) Whether the addition made on account of unexplained money under section 69A was justified. (ii) Whether the addition made on account of unexplained investment under section 69 was justified. (iii) Whether the addition made on account of short-term capital gain was justified.

Issue (i): Whether the addition made on account of unexplained money under section 69A was justified.

Analysis: The cash deposits were supported by a cash book and a monthly cash summary showing availability of withdrawn cash for redeposit. The assessee also explained the brokerage income and the source of cash. The books of account were not rejected by the Assessing Officer with valid reasons, and no contrary material was brought to show generation of cash from any other source.

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

Issue (ii): Whether the addition made on account of unexplained investment under section 69 was justified.

Analysis: The investment in the property was supported by loan confirmations and banking entries from multiple lenders. Their creditworthiness and the genuineness of the transactions were examined and found acceptable. The assessee's explanation for the source of funds used for the property purchase was supported by the record, and no contrary material was produced to dislodge those findings.

Conclusion: The addition under section 69 was not justified and was rightly deleted in favour of the assessee.

Issue (iii): Whether the addition made on account of short-term capital gain was justified.

Analysis: The purchase deed and agreement of consent were examined together, and the property cost and the assessee's share were worked out on that basis. The record supported the assessee's computation of short-term capital gain, and the Revenue did not bring any contrary evidence to sustain the higher addition.

Conclusion: The addition on account of short-term capital gain was not justified and was rightly deleted in favour of the assessee.

Final Conclusion: The appellate findings deleting all three additions were sustained, and the Revenue's challenge failed in entirety.

Ratio Decidendi: Where cash deposits, investment sources, or capital gain computation are supported by contemporaneous books, confirmations, and documentary evidence, and the Revenue brings no contrary material or valid rejection of accounts, additions for unexplained money, unexplained investment, or higher capital gain cannot be sustained.

---