|Question And Answer|
|Subject:||Addition made on the basis of Excel Sheet|
|Answered by:||Research Team|
|Tags:||dumb document, Excel Sheet, search assessment, serach|
|Date:||November 19, 2022|
Search conducted from unknown party, excel sheet found and some data found in that excel sheet regarding my property. AO can make addition on that basis
Merely on the basis of data found in the excel sheet the addition cannot be made . On the facts of the case as the Excel sheet was found in the premises of third party no addition can be made on the assessment of the assessee. In CIT v. Vatika Landbase Pvt. Ltd. (2016) 383 ITR 320 / 238 Taxman 448 / 136 DTR 262 (Delhi)(HC) held that addition cannot be made on the basis of dumb document . In Common Cause (A Registered Society) v. UOI (2017) 394 ITR 220/245 Taxman 214 (SC) Hon’ble Court held that entries in loose paper sheets are irrelevant and inadmissible as evidence. Followed C.B.I. v. V.C. Shukla  3 SCC 410, In Dhananjay Marketing Pvt. Ltd. and Anr. v. CIT (2021) 212 TTJ 877 (Pune)(Trib.). The Court held that where noting are in the nature of “dump documents” having no evidentiary value, additions cannot be made.
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