SURYADEVARA RADHAKRISHNA,HYDERABAD vs. ACIT., CENTRAL CIRCLE-1(2), HYDERABAD

Facts

During a search operation, documents were found indicating the assessee purchased a property for Rs. 13.60 crores, though it was registered for Rs. 4.60 crores, leading the A.O. to add Rs. 9 crores as unexplained on-money payment. Additionally, Rs. 20,85,000/- cash was found at the assessee's residence and office, which the A.O. added as unexplained money, rejecting the assessee's explanation that it was sourced from declared income.

Held

The Tribunal deleted the addition of Rs. 9 crores for alleged on-money payment, finding no corroborative evidence and noting that the seller denied receiving cash. However, the Tribunal upheld the addition of Rs. 20,85,000/- as unexplained cash, concluding that the assessee could not adequately explain its source despite claiming it was from prior admitted income.

Key Issues

Whether the addition of Rs. 9 crores as unexplained on-money payment for property purchase under Section 69 was justified; and whether the addition of Rs. 20,85,000/- as unexplained cash found during search under Section 69 was justified.