Burden of Proof on Taxpayer: Seized Cash Properly Assessed as Unaccounted Money Under Section 69A and 115BBE

The HC held that the seized cash was properly assessed as unaccounted money under section 69A read with section 115BBE. Despite the appellant's declaration during search operations that the money represented commission income, the court found this mere assertion insufficient without satisfactory explanation supported by material evidence. The appellants' failure to respond to show cause notices demonstrated indifference. The court emphasized that even when an explanation is provided, it must satisfy the Assessing Officer as required by section 69A. Following Shashi Garg, the court affirmed that the burden to explain cash sources rests with the assessee, and this burden was not discharged. The appeal was dismissed. .....

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