Documented partner capital contributions through banking channels can satisfy the assessee's burden against unexplained cash-credit additions.

Documentary evidence of a partner's capital contribution through banking instruments, including pay-in slips, demand-draft details, capital-account entries and the firm's balance sheet, supports the assessee's explanation for a cash credit. Where those materials remain uncontroverted, the absence of a separate partner confirmation does not by itself justify treating the contribution as the firm's unexplained income. The note states that failure to consider such material leads to an incorrect finding that the assessee did not discharge its onus, and that the Section 68 addition was deleted.

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Issues: Whether the addition of a partner's capital contribution as unexplained cash credit under Section 68 was sustainable where the assessee produced documentary evidence of the contribution through banking instruments.

Analysis: The partner had been inducted into the firm, and the credited amount was reflected in the partner's capital account and the firm's balance sheet. The assessee's contemporaneous explanation, pay-in slips, demand-draft details and partner-account records established that the contribution was received through banking instruments. These materials were not controverted. The absence of a separate confirmation from the partner did not displace the documentary evidence or justify treating the contribution as the firm's unexplained income. The authorities failed to consider the material evidence and incorrectly concluded that the assessee had not discharged its onus.

Conclusion: The addition under Section 68 was unsustainable and was deleted in favour of the assessee.

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