Jamna Dass Nikkamal Jain Saraf (P.) Ltd. v. DCIT (2025) 238 TTJ 473 (Chd.)(Trib.).

S. 69A: Unexplained money-Seized Papers-Where seized rough sheets substantially tally with the regular books of account, only unexplained differences can be sustained and not the entire addition. [S.132, 145(3)]

The Tribunal held that the Assessing Officer himself had accepted that nearly 80% of the entries found in the seized documents were duly reconciled with the books of account of the assessee and its related concerns. The seized documents were merely rough memoranda subsequently incorporated into the regular books. In the absence of any evidence of unrecorded money or assets, the CIT(A) was justified in deleting the major addition while sustaining only the minor unexplained differences. However, the addition relating to an alleged opening balance was confirmed as the assessee failed to substantiate the claim with evidence from its books of account. (AY. 2022-23)

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