Ownership requirement for unexplained money addition failed where cash belonged to the company, not the assessee personally.

Section 69A could not be invoked where the Revenue failed to prove that the assessee was the owner of the cash in her own right. The seized digital records and statements showed only that cash generated through over-invoicing belonged to the company and that the assessee acted as a key person handling it; they did not establish personal ownership, personal benefit, or unaccounted assets in her possession. The absence of cogent evidence linking the unaccounted cash to her personal enrichment meant the statutory ownership requirement was not satisfied, so the addition was deleted and that deletion was upheld.

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Issues: Whether addition under section 69A of the Income-tax Act, 1961 was sustainable in the assessee's hands on the basis of cash allegedly generated through over-invoicing by the company and reflected in seized digital records and statements.

Analysis: The cash generation through over-invoicing belonged to the company, and the assessee was found to be only a key person handling the company. The seized material and statements showed that cash was mentioned as being given to her in that capacity, but there was no cogent evidence that she held the money as owner for her personal benefit or that any unaccounted cash, jewellery, or investment was found in her personal possession. The material also did not establish that the company's unaccounted income had been transferred to her for personal enrichment. On these facts, ownership for the purpose of section 69A was not proved.

Conclusion: The addition under section 69A in the assessee's hands was not sustainable and the deletion was upheld.

Ratio Decidendi: For invoking section 69A, the Revenue must establish that the assessee was the owner of the money or other valuable article in her own right and not merely a person associated with the entity that generated the cash.

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