Corroborative evidence is required for suppression-of-sales and unexplained-money additions; unsubstantiated employee statements cannot sustain taxation.

Additions for alleged suppression of sales or unexplained money cannot rest solely on employee statements without corroborative material. The notes state that no unaccounted investment, unexplained asset or expenditure supported the suppression allegation, while the relevant turnover had been disclosed in returns and taxed. They further state that no material established unaccounted cash. The Tribunal's factual findings were not open to reappreciation in the absence of a substantial question of law, resulting in deletion of both additions.

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Issues: (i) Whether additions for alleged suppression of sales could be sustained on employee statements without corroborative material; (ii) Whether cash found with the assessee was taxable as unexplained money.

Issue (i): Whether additions for alleged suppression of sales could be sustained on employee statements without corroborative material.

Analysis: The finding of suppressed sales rested solely on statements, with no corroborative material. There was no unaccounted investment, unexplained asset or expenditure, and the source of the alleged suppressed turnover had been disclosed and included in the returns. The income was also already taxed. The Tribunal's finding was factual and did not warrant interference in the absence of a substantial question of law.

Conclusion: The addition for alleged suppression of sales was rightly deleted, in favour of the assessee.

Issue (ii): Whether cash found with the assessee was taxable as unexplained money.

Analysis: No material substantiated the Revenue's case of unaccounted cash, and the Tribunal's factual finding on the absence of supporting material could not be reappreciated in the appeal.

Conclusion: The cash was not liable to be brought to tax as unexplained money, in favour of the assessee.

Final Conclusion: No substantial question of law arose from the Tribunal's factual findings.

Ratio Decidendi: An addition for suppression of sales or unexplained money cannot be sustained solely on statements where no corroborative material supports the allegation and the relevant income has been disclosed and taxed.

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