Unexplained investment and cash credit additions fail where documentary evidence and banking trail establish the source of deposits.

Section 69 additions for alleged unexplained investment and cash credits were examined against documentary proof showing the source of immovable property payments, bank deposits and cash deposits. The assessee relied on purchase deeds, bank statements, RTGS entries, lender confirmations, PAN details, promissory notes and cash flow statements; the remand report accepted that the property payments were made in FY 2013-14, so registration later did not justify invoking section 69 for the year under appeal. The bank and cash deposits were also supported by banking trails, lender confirmations, agricultural receipts and reconciliations, and the Revenue produced no contrary material. On that footing, the additions were deleted and the revenue appeal failed.

---

---

Issues: Whether additions made as unexplained investment and cash credits under section 69 of the Income-tax Act, 1961, in respect of immovable property payments, bank deposits and cash deposits were sustainable.

Analysis: The assessee produced purchase deeds, bank statements, RTGS entries, confirmations, PAN details, promissory notes and cash flow statements to explain the source of the impugned amounts. The remand report accepted that the property payments were made in Financial Year 2013-14 and not in the year under appeal, so section 69 could not be invoked merely because the sale deeds were registered later. The bank deposits in SBI were supported by confirmations and banking trail of three lenders, and the cash deposits in ICICI Bank were supported by confirmation from the jeweller, agricultural receipts and reconciliations. The Revenue did not bring contrary material to disprove the documentary evidence, and suspicion alone could not sustain the additions.

Conclusion: The additions were rightly deleted and the revenue appeal failed.

---