ACIT v. Jotindra Steel & Tubes Ltd. (2022) 94 ITR 359 (Delhi) (Trib.)

S. 69A : Unexplained money-Search of third party-Noting extracted from computer file-Addition cannot be made on presumptions.

Held that addition cannot be made due to some noting found in some file extracted from the computer of one, clearly establishes that the provisions of section 69A do not apply. More importantly, there is no mention of the assessee’s name in the impugned document. The AO has simply assumed that the reference to the impugned amount is in relation to the assessee. No addition can be made on the basis of presumptions and surmises.(AY. 2013-14)