Allowing the appeal the Court held that there was no incriminating material seized, which could suggest that the assessee had paid any on-money. The Assessing Officer had relied upon only two circumstances, firstly, the seized documents, which did not bear any signature, secondly, on the statement of the original owners, wherein the original owners had confirmed on oath the actual value of the land. One of the original owners of lands had stated on oath that a police complaint was given against him and therefore, he had given statement against the purchaser before the Income-tax authorities and subsequently, retracted it. In the circumstances, the assessment order passed based on the seized material and the statements, which had been redressed, was perverse. The Assessing Officer had no material to hold that the assessee had paid any on-money. Order of Tribunal is set aside. (AY.BP. 1990 to 2001)