Held that the AO has not conducted any independent enquiry with the customs authorities, shipping agents, suppliers, etc. Further, the AO did not bring any corroborative materials and also did not conduct any independent enquiry to prove the genuineness of these documents and to disprove the explanations of the assessee. In view of the foregoing discussions, these documents, being loose papers, should be classified as dumb documents only and the AO could not have placed reliance on these documents in order to make the impugned additions. The documents found in the phone of the partner of the assessee-firm cannot be considered to be credible evidence which would support the additions made by the AO in both the years, they can be considered to be dumb documents only, since they were not corroborated by any other independent documents or enquiry. Accordingly, the additions made by the AO in both the years are deleted. (AY. 2020-21,  2021-22)