Section 69A unexplained-money addition failed where bank credits were shown as agency receipts passed onward, leaving only commission income.

Cash and credit entries in an assessee's bank accounts were held not to be unexplained money under section 69A where the assessee acted as a Business Correspondent Agent and produced authorisation, bank statements, a transaction chart, and supporting material showing that customer collections were transferred onward, leaving only commission income. The Tribunal found that the deposited sums were received for transmission in the course of agency activity and were not owned by the assessee. As the statutory precondition for section 69A-assessee's ownership of unexplained money-was not met, the addition of the aggregated amount was deleted.

---

---

Issues: Whether the cash and credit entries aggregating to Rs. 1,70,53,900 credited in the assessee's bank accounts were assessable as unexplained money under section 69A of the Income-tax Act, 1961, or represented business receipts received in the course of agency activity for onward transfer.

Analysis: The assessee produced the authorisation from Airtel Payments Bank Ltd., bank statements, a detailed transaction chart, and material showing that the amounts collected from customers were transferred onward, leaving only commission income in its hands. The Tribunal accepted that the assessee functioned as a Business Correspondent Agent and that the deposited sums were not owned by the assessee but were received for transmission in the course of business. In these circumstances, the precondition for invoking section 69A, namely ownership of unexplained money by the assessee, was not satisfied.

Conclusion: The addition of Rs. 1,70,53,900 under section 69A was not sustainable and the issue was decided in favour of the assessee.

---