Bank credits supported by confirmations cannot be fully treated as unexplained money, though income may be estimated on reasonable commission basis.

Bank credits supported by company confirmations and surrounding transaction patterns were treated as receipts in a commission agency capacity, so the entire deposits could not be assessed as unexplained money under section 69A. However, because formal contracts, purchase bills and complete primary evidence were absent, the claim of only 1.5% commission was rejected and income was reasonably estimated at 8% of the credited amount. The Revenue's challenge to the restricted addition failed, and the estimated addition sustained by the first appellate authority was affirmed.

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Issues: Whether the deposits in the assessee's bank account were liable to be treated as unexplained money under section 69A, and whether the restriction of the addition to 8% of the credited amount on an estimated commission basis was justified.

Analysis: The assessee produced confirmations from companies showing that the receipts represented sale proceeds of fruits routed through him as an intermediary for farmers. The pattern of bank transactions and withdrawals supported the existence of a commission agency business, while the Assessing Officer had added the entire credits without giving due weight to the confirmations and withdrawals. At the same time, the absence of formal contracts, purchase bills, and complete primary evidence justified rejection of the claim that only 1.5% commission was earned. On the material available, the estimation of commission income at 8% was found to be a fair and reasonable approach.

Conclusion: The addition under section 69A was not warranted in full, and the restriction of income to 8% of the credited amount was upheld; the Revenue's challenge failed.

Final Conclusion: The estimated addition sustained by the first appellate authority was affirmed, resulting in dismissal of the Revenue's appeal.

Ratio Decidendi: Where bank credits are supported by confirmations and surrounding circumstances showing receipt in an agency capacity, the entire credits cannot be treated as unexplained money, but income may still be estimated at a reasonable percentage if complete primary evidence is lacking.

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