The assessee was a non-resident Indian individual and acquired two properties in Mumbai for a total consideration of Rs. 16,63,21,060. The purchase consideration was discharged by the assessee partly by way of direct remittance from abroad to the vendor and partly through banking channels from the Bank of Baroda, Dubai account held by the assessee to the SBI NRE SB Account. The assessee explained that the sources for deposit in the Bank of Baroda were sale proceeds of gold bars to two companies namely, SJ and VG, Dubai and maturity proceeds of fixed deposits belonging to a company owned by the assessee and his wife. The Assessing Officer disbelieved the explanation of the assessee on the ground that the activity of selling gold in Dubai was unusual and there was no proof of existence of stock of gold in Dubai and rejected the certificates as not reliable since they were not signed by the director. The tribunal held that the conclusion reached by both the Assessing Officer and the Commissioner (Appeals) was based on conjectures, surmises and presumptions. The assessee had filed copies of the certificate of incorporation of the company in 2007 and of the certificate from the Bank of Baroda certifying that an amount of AED 99,83,455 equivalent to Rs. 16,97,18,735 was credited to the account of assessee and his wife. The assessee had discharged the primary onus upon him, by explaining the sources of the deposits, credits in the bank from where the remittances were brought to India by evidence such as confirmation from the Bank of Baroda, Dubai that the deposits represent maturity proceeds of fixed deposits held in the name of the company and purchase invoices of gold by the two companies and as well as copies of cheques issued in favour of the assessee. Both the Assessing Officer as well as the Commissioner (Appeals) had merely rejected the explanation without giving any cogent reasons and without rebutting the evidence led by the assessee. Therefore, it could not be said that the assessee had failed to render a plausible and credible explanation as to the source of money for the acquisition of the two properties. Even if, in the opinion of the Assessing Officer the explanation given by the assessee was not satisfactory, no addition could be made. (AY. 2014-15).