> **Order:** ITA No. 235/RPR/2025 (ITAT Raipur SMC), Assessment Year 2019-20, pronounced 28.07.2025.

## Facts

Ground 2 challenged a Rs.1,98,000 addition under section 69 towards cash paid for purchase of land, and ground 3 a Rs.13,15,000 addition under section 69A — Rs.10,75,000 received from the assessee's spouse and Rs.2,40,000 of cash deposits — with a further ground against applying section 115BBE to these additions.
Ground 1, on a section 56(2)(x)(b) land-valuation difference of Rs.2,05,800, was not pressed and was dismissed.

## Issues

Whether section 69 and 69A additions survive where the assessee's documentary trail was filed before the Assessing Officer and never disproved.

## Holding

On section 69, the Tribunal recorded that the documentary evidence had been filed before the Assessing Officer, that the Departmental Representative did not contend it was additional evidence, and that an addition based on summary observation without legal validity cannot sustain — directing deletion of Rs.1,98,000 and allowing the ground.
On section 69A, the spouse's Rs.10,75,000 stood supported by mirror bank entries, account confirmation, bank statements, return and computation, all furnished and never disproved as false or fabricated, while the Rs.2,40,000 deposit stood against sufficient past-savings cash balance.
Suspicion however strong cannot take the place of proof, and assessments cannot rest on pure guess-work without evidence or material.
The Departmental Representative could neither refute the record nor point to any unexplained nature or source, so the section 69A addition was held misplaced and directed to be deleted.
The appeal was partly allowed and the order pronounced on 28.07.2025.

## Why a client would care

Cash-credit and money additions are answered on paper filed and never disproved — mirror bank entries, confirmations, returns — because suspicion, however strong, is not proof on this reasoning.

## Questions clients ask

**Q1. Rs.1,98,000 was added under section 69 on a summary observation. Did it stand?**

No — the documentary evidence was already before the Assessing Officer and was never disproved, so the addition was deleted.

**Q2. What happened to the Rs.13,15,000 section 69A addition?**

It was deleted too: the spouse’s Rs.10,75,000 was supported by mirror bank entries, account confirmation, bank statements, return and computation, and was never shown false or fabricated.

**Q3. Can suspicion substitute for evidence?**

The Tribunal held suspicion, however strong, cannot take the place of proof.

## Disclaimer

*This note summarises a Tribunal order for general information. It is not professional advice and does not predict the outcome of any other case. Tax and company-law positions depend on facts and dates; take a written opinion before you act. Harun Raaj & Associates is a Chartered Accountants firm in Visakhapatnam.*

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