Unexplained cash deposit addition deleted after bank certificates showed fixed deposit accounts and the assessee discharged initial onus.

Bank certificates showing that the accounts relied on by the Assessing Officer were fixed deposit accounts opened earlier and closed on different dates were sufficient to discharge the assessee's initial onus on source and nature of the transaction. Because the addition was made in the faceless regime without proper verification of those documents, and the RTI material did not support the quantum added, the record did not justify treating the amount as unexplained income. The ITAT Ahmedabad deleted the addition of Rs. 52,00,000 and accepted the assessee's explanation.

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Issues: Whether the addition of Rs. 52,00,000 as unexplained cash deposit was sustainable when the assessee produced bank certificates showing that the alleged accounts were fixed deposit accounts opened earlier and closed on different dates, and whether the assessee had discharged the initial onus regarding the source and nature of the transaction.

Analysis: The assessee produced bank certificates showing that the three accounts relied upon by the Assessing Officer were fixed deposit accounts opened on 17.08.2013 and closed on 28.04.2014 and 07.01.2015. On that material, the assessee discharged the initial onus. The addition was nevertheless made in the faceless regime without verification of those documents, and the RTI material did not support the quantum of addition made by the Assessing Officer. The record therefore did not justify treating the amount as unexplained income in the assessee's hands.

Conclusion: The addition of Rs. 52,00,000 was deleted and the issue was decided in favour of the assessee.

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