On-money addition fails without corroboration when banking records support accounted payment and no cash trail links the assessee.

On-money addition for alleged cash payment on purchase of an industrial unit could not be sustained where the Revenue relied only on third-party search material and a general statement from the builder's representative, without independent corroboration linking the assessee to any cash trail. Registered agreement, builder's receipts, bank statements and an affidavit supported payment through accounted banking channels, while the seized material referred to another name. In the absence of primary evidence or a tested statement establishing actual cash payment by the assessee, the addition under section 69C and the consequential taxation under section 115BBE were deleted.

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Issues: Whether the addition of Rs. 30,00,000 as alleged on-money payment for purchase of the industrial unit was sustainable in the absence of independent corroboration and in the face of documentary evidence showing payment through banking channels.

Analysis: The addition rested on search material relating to a third party and a general statement of the builder's representative, without independent verification linking the assessee to any cash payment. The assessee had furnished the registered agreement, builder's receipts, bank statements and affidavit indicating that the consideration was paid through accounted channels. The seized material also referred to another name, and no primary evidence, cash trail, or tested statement was brought on record to establish actual payment by the assessee. In these circumstances, the third-party material was held insufficient to sustain the addition.

Conclusion: The addition under section 69C and the consequential taxation under section 115BBE were deleted, and the assessee succeeded on the substantive ground relating to the on-money addition.

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