There was no mention of the assessee name anywhere in the seized documents and none of the searched parties agreed that they have undertaken any cash transaction with the assessee.  The AO had not conducted any independent enquiry or made any efforts to corroborate the seized pages or link it to assessee. The entire assessment has been made without bringing on record any evidence but merely relying on statements made by persons and AO’s perceptions/presumptions. It was also held that the electronic data cannot be relied upon in the absence of requisite certificate under Section 65B(4) of the Indian Evidence Act especially when the contents of the pen drive are disputed. (AY. 2008-09, 2009-10, 2010-11)