Unexplained Money under Section 69A: Locker cash linked to group company records could not be added to the assessee.

Cash found in a locker cannot be taxed as unexplained money under section 69A where surrounding records show it formed part of a group company's cash balance and no contrary evidence disproves that explanation. The ITAT noted that the Assessing Officer's attribution of the seized cash was inconsistent with the seized books and post-search chart, while the company's cash book and related records supported the claim that the cash was cash in hand of the group company. As the company's cash balance was not doubted in its own assessment and ownership by the assessee alone was not established, the addition was deleted.

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Issues: Whether the addition made as unexplained money under section 69A, on account of cash found in a locker in the assessee's name, was sustainable when the surrounding material showed that the cash formed part of the cash balance of a group company and no contrary material was brought to disprove that explanation.

Analysis: The cash balance reflected in the seized books and post-search chart was not uniformly attributed by the Assessing Officer, and the working of the amount treated as belonging to the assessee was found to be inconsistent. The explanation that the cash kept in the locker represented cash in hand of the group company was supported by its cash book and related records, and that company's cash balance had not been doubted in its own assessment. In the absence of any contrary evidence showing that the cash belonged exclusively to the assessee, the addition could not be sustained merely because the locker stood in the assessee's name.

Conclusion: The addition under section 69A was deleted and the assessee succeeded on the issue.

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