Held, that apart from referring to this bank statement to substantiate his claim that the cash deposited in the bank account was out of cash withdrawals, no other document was placed on record to prove the utilisation of cash withdrawn by the assessee. The assessee had also not established the link between cash withdrawals and cash deposits in his bank account. There was no proof regarding other transactions in the bank account. Merely because cash withdrawals by the assessee were more than the cash deposited in the bank account that could not lead to the conclusion that the cash deposit was out of the cash withdrawal without complete details of the utilisation of money. Thus, in the absence of necessary explanation and details, there was no infirmity in the findings of the Commissioner (Appeals)(AY. 2012–13)
Zakir Ali Yarbali Khan v. ITO (2023)101 ITR 35 (SN)(Mum) (Trib)
S. 68 : Cash credits-Income from undisclosed source-claim that cash deposited was out of cash withdrawals-No document to substantiate claim-Link not established-Addition is justified.