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Issues: Whether the differential amount between the bank credits and the turnover disclosed in the profit and loss account could be treated as unexplained money under section 69A of the Income-tax Act, 1961.
Analysis: The assessee produced books of account, audited financial statements, bank statements, invoices, lorry receipts, commission statements and a reconciliation explaining that a substantial part of the bank deposits represented sale proceeds of consignment transactions handled as a del-credere commission agent for principal suppliers. The books were not rejected under section 145(3) of the Income-tax Act, 1961, and no contrary material was brought to disprove the business model or the reconciliation. Mere comparison of gross bank credits with turnover disclosed in the profit and loss account was held insufficient to conclude that the differential amount constituted unexplained money.
Conclusion: The addition under section 69A of the Income-tax Act, 1961 was unsustainable and was directed to be deleted, resulting in relief to the assessee.