Kuldeep Kumar v. ITO (2022) 213 DTR 201/217 TTJ 632(Asr)(Trib)

S. 69A : Unexplained money-Cash deposited in the bank-Explanation was not satisfactory-Addition was justified-Income from undisclosed source-Stock valuation-Suppression of stock-Addition was deleted. [S. 69, 145]

Held that  the  contention of the assessee that the cash deposited in his bask account was sourced from the funds lying in the common pool with him and his son, being an explanation devoid of any merit  cannot be accepted at the relevant point of time. e. when the assessee deposited the money in his bank account the assessee was the owner of the same which was not recorded in his books of accounts and there being no explanation about the nature and sources of the acquisition of the same the impugned amount was nightly treated as unexplained money and brought to tax under S. 69A. Tribunal also held that once the CIT(A) has relied on the revised stock statement made  by the assessee in the course of assessment proceedings to vacated the addition made by the AO on account of alleged sales of bullion outside the books of account, there was no justification to sustain the addition of account of alleged suppression of closing stock of bullion by rejecting the very same revised stock statement and relying upon the original stock statement transactions were not reflected.  (AY. 2013-14)