Section 69 Addition Deleted – Cash Availability Human Probabilities Accepted: ITAT Bangalore

Siddegowda Channa Basavaiah Vs ITO (ITAT Bangalore) The Bangalore ITAT deleted the addition of ₹4.81 lakh made under Section 69, holding that the assessee had reasonably explained the source of cash deposits based on surrounding circumstances and human probabilities. The AO had treated excess cash deposits as unexplained due to: Lack of one-to-one correlation between withdrawals and deposits, Time gap between withdrawals and redeposit, Absence of documentary proof for cash received from relatives. However, the Tribunal held: Strict one-to-one nexus is not required; once overall cash avail...