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Issues: (i) Whether the addition sustained on account of cash deposits during the demonetisation period was justified where the assessee claimed availability of cash from the proprietorship concern and realisation from debtors. (ii) Whether the addition on account of unexplained investment in acquisition of immovable property required interference or remand for verification.
Issue (i): Whether the addition sustained on account of cash deposits during the demonetisation period was justified where the assessee claimed availability of cash from the proprietorship concern and realisation from debtors.
Analysis: The assessee's claim rested on a reconciliation of capital balance and alleged realisation from debtors of the closed proprietorship concern. No supporting evidence of realisation from debtors was produced, and the attempt to rely on a cash book at the appellate stage was not accepted, particularly since regular books of account were not maintained. Credit had already been granted for the cash in hand reflected in the assessee's balance sheet, and no further infirmity was shown in the appellate order sustaining the balance addition.
Conclusion: The sustained addition was upheld and remained against the assessee.
Issue (ii): Whether the addition on account of unexplained investment in acquisition of immovable property required interference or remand for verification.
Analysis: The assessee asserted that the property had been booked earlier and that payments were made in prior years, but the material produced did not substantiate the claim. In the absence of adequate supporting evidence, the matter required factual verification by the Assessing Officer to examine the source and timing of the payments in accordance with law.
Conclusion: The issue was remanded to the Assessing Officer for fresh examination, with the assessee required to furnish supporting details.
Final Conclusion: The assessee obtained relief only on the property-investment issue by way of remand, while the cash-deposit addition was sustained.
Ratio Decidendi: A claim explaining cash deposits or investment must be supported by credible evidence; where the explanation is unsubstantiated, the addition may be sustained, while inadequately verified factual claims may be remanded for fresh examination.