Section 69A addition on cash deposits fails where supported explanations and record evidence establish the source.

Cash deposits were held not to constitute unexplained money under section 69A where the assessee supported the source with material showing rental income from four flats, accumulated savings and a registered sale deed for agricultural land. In the absence of any contrary evidence from the Revenue to disprove the explanation or show that the deposits were unexplained, the addition could not be sustained. The tribunal therefore directed deletion of the addition and accepted the assessee's explanation as sufficient on the record.

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Issues: Whether the addition made under section 69A in respect of cash deposits of Rs. 16,20,000 was sustainable when the assessee explained the source as accumulated savings, rental income and sale proceeds of agricultural land.

Analysis: The explanation offered for the deposits was supported by material on record showing rental income from four flats, and there was no contrary evidence from the Revenue to negate the possibility of accumulated savings. The claim relating to Rs. 4,00,000 from sale of agricultural land was also substantiated by a registered sale deed produced at the hearing. In the absence of evidence showing the deposits to be unexplained money, the addition could not be sustained under section 69A.

Conclusion: The addition was held to be unsustainable and was directed to be deleted, in favour of the assessee.

Ratio Decidendi: Where the assessee offers a plausible and supported explanation for cash deposits and the Revenue brings no contrary evidence to disprove the source, an addition as unexplained money under section 69A cannot be sustained.

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