ACIT v. Chhattisgarh Distilleries Ltd. (2025) 238 TTJ 774 / 177 taxmann.com 257 (Raipur)(Trib.)

S. 69: Unexplained investments-Undisclosed Income-Loose papers-Addition based on dumb documents-Addition was deleted.[S.69C, 132, 153A]

Loose papers found during the course of the search, which were undated, unsigned and not supported by any corroborative evidence, could not form the basis for addition. The Revenue failed to establish any nexus between the documents and the assessee or any evidence of unaccounted sales or tax evasion. The director had neither admitted to undisclosed sales nor had any enquiry been made to the person who could explain the documents. Addition based merely on presumption and conjectures was rightly deleted. (AY. 2017-18).

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