Unexplained cash credit addition failed where no exact transaction details or supporting evidence established the alleged accommodation entry.

An addition under section 68 based on an alleged accommodation entry could not be sustained where the assessment order did not identify the exact transactions, the source details, or supporting evidence, and no proper enquiry was made. The assessee denied the transaction, yet the assessing authority made the addition without verifying the factual position or confronting that denial with material evidence. The first appellate authority found that the addition rested only on a bare reference to search findings, without discussion of the evidence, the statement under section 132(4), or any enquiry establishing the credit as unexplained. That finding was not controverted by the Revenue, so the deletion of the addition was upheld.

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Issues: Whether the addition of Rs. 59,97,950 made under section 68 on the basis of an alleged accommodation entry could be sustained when the assessment order did not disclose the exact transactions, the source details, or supporting evidence and no proper enquiry was made.

Analysis: The addition was made on the footing that the assessee had received an accommodation entry from a third party, but the assessment order did not mention the precise date of the transactions, the persons or concerns involved, or any supporting material showing receipt of the alleged amount. The assessee had denied the transaction, yet the assessing authority made the addition without verifying the factual position or confronting the denial with evidence. The first appellate authority found that the addition was based on a bare reference to search findings, without discussion of the evidence, statement under section 132(4), or any enquiry establishing the credit as unexplained. The appellate findings were not controverted by the Revenue.

Conclusion: The deletion of the addition was upheld and the Revenue's challenge failed.

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