The Tribunal held that the addition under section 69A could not be sustained merely on the basis of loose papers and statements recorded from finance brokers during a search conducted prior to the commencement of the relevant previous year. The assessee had promptly retracted the statement recorded during the survey, alleging coercion, and the Revenue failed to produce any corroborative evidence such as statements of brokers, borrowers or other material linking the assessee with alleged cash loans. The seized papers were merely “dumb documents” incapable of establishing undisclosed investments. In the absence of independent evidence, no adverse inference could be drawn, and the addition was deleted. (AY. 2020 21)
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