The AO made addition on the basis of loose papers found during  the search proceedings. CIT (A) deleted the addition. On appeal by the revenue the Tribunal held that CIT(A) had overlooked the provision of S.132(4A) of the Act hence  allowed the appeal of the revenue. On appeal the High Court held that, The Tribunal only on basis of presumption u/s. 132(4A) reversed the finding of the CIT(A), without recording any finding as to how the loose sheets which were recovered during search were linked with the assesee. In the absence of corroborative evidence, the Tribunal was not justified in reversing the finding of the CIT(A). The matter is set aside to decide on merit. (ITA No. 357 of 2010 dt. 13-11-2019)