Explained cash deposits and reconciled commission records led to deletion of all additions in the tax appeal.

ITAT Ahmedabad deleted additions where the assessee substantiated cash deposits with financial statements, customer-wise ticket sale details and bank statements showing travel-business collections, so the cash was not treated as unexplained money under section 69A. It also deleted the commission addition on inter se transactions with M/s. Arihant Trip Solution (LLP) because the assessee's account records showed purchase and loan entries and were not properly considered. The addition based on the difference between commission in the return and Form 26AS also failed, as the figures were reconciled and no verified discrepancy remained. The appeal succeeded on all adjudicated grounds.

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Issues: (i) Whether cash deposits in the assessee's bank accounts were liable to be treated as unexplained money under section 69A of the Income-tax Act, 1961. (ii) Whether the addition of commission at 4% on the amount shown in the inter se transactions with M/s. Arihant Trip Solution (LLP) was justified. (iii) Whether the addition made on account of difference between commission reflected in the return of income and Form 26AS was sustainable.

Issue (i): Whether cash deposits in the assessee's bank accounts were liable to be treated as unexplained money under section 69A of the Income-tax Act, 1961.

Analysis: The assessee furnished financial statements, customer-wise ticket sale details and bank statements showing that the cash deposited in the HDFC Bank accounts represented collections received from customers in the travel business. The material on record was not properly considered by the lower authorities.

Conclusion: The cash deposits were explained and the addition was deleted in favour of the assessee.

Issue (ii): Whether the addition of commission at 4% on the amount shown in the inter se transactions with M/s. Arihant Trip Solution (LLP) was justified.

Analysis: The assessee produced the account details of M/s. Arihant Trip Solution (LLP), showing the transactions as purchase and loan entries. The Assessing Officer did not take cognizance of these records before making the addition.

Conclusion: The addition of Rs. 2,80,000 was deleted in favour of the assessee.

Issue (iii): Whether the addition made on account of difference between commission reflected in the return of income and Form 26AS was sustainable.

Analysis: The difference amount was not verified, and the figures in Form 26AS were found to tally with the return of income filed by the assessee.

Conclusion: The addition did not survive and was deleted in favour of the assessee.

Final Conclusion: The appeal succeeded on all adjudicated grounds and the assessment additions were set aside.

Ratio Decidendi: When the assessee substantiates cash deposits and commission receipts with contemporaneous books, bank records, and statutory statement reconciliation, an addition for unexplained money cannot be sustained without proper verification of the material evidence.

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