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Departmental appeal against deletion of addition of Rs.23,000 by AAC. Analysis: The case involved a departmental appeal against the deletion of an addition of Rs.23,000 by the AAC. The assessee, an individual employed by a corporation, had encashed 23 high denomination notes, leading the ITO to add Rs.23,000 as income from other sources. The assessee contended that the amount was encashed by his wife from savings out of family expenses. The AAC, after considering the facts, deleted the addition, stating that the ITO had no justification to hold it as undisclosed income. The AAC reasoned that the wife's savings were plausible given the husband's earnings and investments, concluding that the addition was unjustified. The department appealed, arguing that the AAC lacked sufficient grounds to delete the addition, while the assessee's counsel supported the AAC's decision based on the facts and materials presented. The AAC's decision to delete the addition was upheld by the tribunal. The AAC had thoroughly examined the facts, including the source of the high denomination notes being the assessee's wife, the assessee's income from salary and interest, and his investments. The tribunal agreed that considering the assessee's total earnings, it was plausible for his wife to save Rs.23,000. The tribunal found the AAC's reasoning fair and maintained the deletion of the addition. Consequently, the appeal against the AAC's decision was dismissed, affirming the deletion of the Rs.23,000 addition as income from other sources.
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