During the course of search, cash was seized and the assessees filed returns declaring ₹50,00,000 and ₹35,00,000 respectively as commission income. However, except for a bald statement that the amounts represented commission, no details or material explaining the nature and source of such receipts were furnished despite issuance of show-cause notices. The assessees did not respond to the notices. The Court held that under section 69A, the burden lies on the assessee to satisfactorily explain the nature and source of money found in his possession. Mere declaration during search or disclosure in return is not sufficient unless supported by credible material. Even where an explanation is offered, it must be satisfactory in the opinion of the Assessing Officer. In the present case, there was no explanation at all. The seized cash, not being properly explained, constituted unexplained money within the meaning of section 69A and was liable to be taxed under section 115BBE. The contention that declaration of income as commission was sufficient to take the case outside the purview of section 69A r/w section 115BBE was rejected. (AY. 2021-22)