Protective addition on joint bank account cash deposits deleted where deposits matched family land sale proceeds.

Protective addition for cash deposits in a joint bank account was unsustainable where the evidence showed the account was mainly operated by the assessee's father and the deposits matched sale proceeds of agricultural land owned by other family members. Since the related land sale transactions and their tax treatment had already been examined in those family members' cases, mere joint holding of the account did not justify taxing the deposits in the assessee's hands. The addition was deleted in favour of the assessee.

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Issues: Whether the protective addition of cash deposits made in a joint bank account, stated to be sourced from sale proceeds of agricultural land owned by other family members, could be sustained in the assessee's hands.

Analysis: The assessee showed that the impugned bank account was primarily operated by his father and that the cash deposits corresponded to sale proceeds of agricultural land belonging to other female family members. The record also showed that the related sale transactions and corresponding tax treatment had already been considered in the cases of the family members who were connected with the land. In these circumstances, the material on record did not justify fastening the cash deposits on the assessee merely because he was a joint holder of the bank account.

Conclusion: The protective addition was not sustainable in law and was deleted in favour of the assessee.

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