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Issues: Whether the cash deposits made during the demonetization period were liable to be treated as unexplained money under section 69A of the Income-tax Act, 1961, and whether the Revenue's objection based on alleged additional evidence required restoration of the matter for fresh adjudication.
Analysis: The assessee had maintained audited books of account, cash book, bank book and supporting financial records. The cash deposits were explained as being out of available cash balance arising from business receipts and earlier cash withdrawals. The Assessing Officer had not pointed out specific defects in the books, had not rejected the book results, and had brought no tangible material to show that the withdrawn cash had been diverted for any other purpose. The comparative cash history for earlier and later years showed a consistent pattern of cash handling in a cash-oriented business. The chart relied upon before the first appellate authority was only a compilation derived from already filed cash book and bank book, and therefore did not constitute impermissible additional evidence warranting remand.
Conclusion: The cash deposits were explained on the basis of record and could not be added as unexplained money under section 69A. The objection founded on alleged additional evidence was also rejected.
Ratio Decidendi: Where cash deposits are supported by audited books and a consistent cash-flow pattern, and the Revenue fails to show that the withdrawn cash was used elsewhere, an addition under section 69A cannot rest on suspicion alone.
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