CBI v. V.C. Shukla

3 SCC 410Supreme Court of India1998#161 most cited

What is CBI v. V.C. Shukla authority for?

Loose sheets of paper, excel sheets, or diaries, often referred to as 'dumb documents,' are wholly irrelevant as evidence and not admissible under Section 34 of the Evidence Act if they lack evidentiary value. Additions to income cannot be made solely based on such documents without corroborating, reliable, and admissible evidence supported by other circumstances.

442

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2003 to 2026.

Also referred to as

CBI v. V.C. Shukla · evidentiary value · loose sheets · dumb documents · Section 34 Evidence Act · Section 292C · admissibility of evidence · books of account · uncorroborated evidence · Section 132(4A)

Also reported as

138 Taxmann 1903 AIR 410

Sections most often in play

Section 143(3)Section 132Section 153CSection 292CSection 153ASection 132(4)Section 132(4A)Section 115BBE

Issues it is cited on

dumb documentssection 132(4a)section 292csection 34section 269tsection 158bdloose papersonus of proofsection 269sincome tax settlement commissiondocuments seizedsection 269ss

Judgments citing CBI v. V.C. Shukla

Deputy Commissioner of Income-Tax, Queens Road, Bengaluru vs. Shri Kempareddy Govindraju, Domlur, Bengaluru

ITA 1292/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Jan 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

For Appellant: Shri. V. Chandrasekhar, ARFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

…therefore cannot advance the case of the department and cannot be relied upon to sustain the additions on the facts and circumstances of the case. Strong reliance in this regard is placed on the judgement of the Hon’ble Apex Court in CBI vs V.C.Shukla (1998) 3 SCC 410. v. The learned CIT(A) failed to also appreciate that it is well settled law that unless the author of the document is examined who alone can explain the entries and the transactions therein, no reliance can be placed on such document, more so when the document is dumb document and is incapable of speaking for itself. Consequently, the author of th…

Deputy Commissioner of Income-Tax, Central Circle-2(3), Benglauru vs. Shri Kempareddy Govindraju, Domlur, Bengaluru

In the result the appeals of the assessee in ITA No’s 1022 to 1024/ Bang/ 2024, for the Assessment Years 2014-15, 2015-16 and 2016-17 are allowed and the appeals of the Revenue in ITA Nos

ITA 1291/BANG/2024[2015-16]Status: DisposedITAT Bangalore31 Jan 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

For Appellant: Shri. V. Chandrasekhar, ARFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

…ang/2024 Page 15 of 155 the case of the department and cannot be relied upon to sustain the additions on the facts and circumstances of the case. Strong reliance in this regard is placed on the judgement of the Hon’ble Apex Court in CBI vs V.C.Shukla (1998) 3 SCC 410. v. The learned CIT(A) failed to also appreciate that it is well settled law that unless the author of the document is examined who alone can explain the entries and the transactions therein, no reliance can be placed on such document, more so when the document is dumb document and is incapable of speaking for itself. Consequently, the author of t…

Shri. Kempareddy Govindraj, Bengaluru vs. Assistant Commissioner of Income Tax, Central Circle-2(3), Bengaluru

ITA 1022/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Jan 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

For Appellant: Shri. V. Chandrasekhar, ARFor Respondent: Shri. Sridhar E, CIT(DR)(ITAT), Bangalore
Section 131(1)Section 132Section 132(1)Section 143(3)Section 153ASection 250

…efore cannot advance the case of the department and cannot be relied upon to sustain the additions on the facts and circumstances of the case. Strong reliance in this regard is placed on the judgement of the Hon’ble Apex Court in CBI vs V.C.Shukla (1998) 3 SCC 410. v. The learned CIT(A) failed to also appreciate that it is well settled law that unless the author of the document is examined who alone can explain the entries and the transactions therein, no reliance can be placed on such document, more so when the document is dumb document and is incapable of speaking for itself. Consequently, the author…

Deputy Commissioner of Income Tax, Central Circel-2(1), Nagpur vs. M/S. Metrocity Homes, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 164/NAG/2023[2017-18]Status: DisposedITAT Nagpur21 Jan 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Suren Duragkar a/wFor Respondent: Shri Sandipkumar Salunke
Section 132Section 153C

…ty Homes A.Y. 2017–18 sum so credited may be charged to income tax as the income of the assessee of that previous year." The language of the Law is vague and subjective, thus making us rely on an Apex court decision in the case of CBI vs. V.C. Shukla ((1998) 3 SCC 410), wherein the relevant portion reads thus: "Collection of sheet fastened or bound together so as to form material whole. Loose sheets or scraps of paper cannot be termed as books." In this regard, it is relevant to extract Section 69A of the Act, which reads thus: "69A. Where in any financial year the assessee is found to be the owner of any money,…

ACIT., Central Circle 2(2), Hyderabad vs. Spectra India Eco Projects Private Limited, Hyderabad

In the result, all the appeals filed by the assessee are dismissed

ITA 797/HYD/2024[2019-20]Status: DisposedITAT Hyderabad08 Jan 2025AY 2019-20

Bench: Shri Laliet Kumar, Judicial Member, Shri Madhusudan Sawdia (Accountant Member)

Section 132Section 153A

…Ravi Prasad. without any reference to the finance business of the assessee. The learned counsel for the assessee, further referring to certain judicial precedents, including the decision of the Hon’ble Supreme Court in the case of CBI Vs. V.C. Shukla (1998) 3 SCC 410 (SC), submitted that, loose sheets or diaries are not books of accounts, and on the basis of such evidences, no additions can be made. Further, the assessee and his family members are into the finance business out of their agricultural income, and the same has been offered to tax by his father and also by the assessee HUF. Therefore, once again mak…

DCIT, Ghaziabad vs. M/S. Devidayal Aluminium Industries Pvt. Ltd., Ghaziabad

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2016[2007-08]Status: DisposedITAT Delhi08 Jan 2025AY 2007-08

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…n respect of general civil works at Annupur Power plant. The loose sheets (excel sheets) have no evidentiary value. In Common Cause v. UOI – known as Sahara Diaries case (2017) 394 ITR 220, Hon’ble Supreme Court quoting with approval CBI v. V.C. Shukla (1998) 3 SCC 410 has observed at page 229 that: “loose sheets of papers are wholly irrelevant as evidence being not admissible under section 34 so as to constitute evidence with respect to the transactions mentioned therein being of no evidentiary value”. At page 230, it was further observed that: “There has to be some relevant and admissible evidence and some coge…

Shri Satish Chandra Katta, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 438/JPR/2018[2012-13]Status: DisposedITAT Jaipur31 Dec 2024AY 2012-13
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

…levant extract of the submissions filed by the assessee, which are identical for both assessment years on the legal issue, along with the contentions raised, is set out hereunder: “1.4 In the case of Central Bureau of Investigation v. V. C. Shukla & Ors. 1998 3 SCC 410 popularly known as Jain Hawala Case where Section 34 of the Evidence Act, 1872 has been explained. In this case it is held that entries in Jain Notebooks held on facts admissible under Section 34, but file containing loose sheets of papers are not "book" and hence entries therein not admissible under Section 34. Further it was also held in this cas…

M/S Shrigopal Rameshkumar Sales Pvt. Ltd, Nagpur vs. Assistant Comissioner Central Circle 1(3), Nagpur

In the result, appeal filed by the assessee is allowed

ITA 53/NAG/2020[2015-16]Status: DisposedITAT Nagpur30 Dec 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kapil HiraniFor Respondent: Shri Sandipkumar Salunke

…notings. 13 Shrigopal Rameshkumar Sales Pvt. Ltd. The liability to tax any income shall arise only when such jottings or notings proved to be forming part of income not disclosed by assessee, for the purposes of assessment. Refer, CBI v. V.C. Shukla [1998] 3 SCC 410/[1998] 1998 taxmann.com 155 (SC), Common Cause (A Registered Soci- ety) v. UOI [2017] 77 taxmann.com 245/[2017] 245 Taxman 214 (SC).” 17. It is trite law that presumption however strong cannot substitute for evidence. “The Hon'ble Supreme Court in the case of Dhakeshwari Cotton Mills Ltd. v. CIT [1954] 26 ITR 775 (SC) and Chuharmal V. CIT (1998)…

Siyaram Exports India Private Limited, Jaipur vs. ITO Ward 6(4), Jaipur

ITA 151/JPR/2024[2013-14]Status: DisposedITAT Jaipur30 Dec 2024AY 2013-14
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

…levant extract of the submissions filed by the assessee, which are identical for both assessment years on the legal issue, along with the contentions raised, is set out hereunder: “1.4 In the case of Central Bureau of Investigation v. V. C. Shukla & Ors. 1998 3 SCC 410 popularly known as Jain Hawala Case where Section 34 of the Evidence Act, 1872 has been explained. In this case it is held that entries in Jain Notebooks held on facts admissible under Section 34, but file containing loose sheets of papers are not "book" and hence entries therein not admissible under Section 34. Further it was also held in this cas…

Siyaram Exports India Private Limited, Jaipur vs. ITO Ward 6(4), Jaipur

ITA 145/JPR/2024[2011-12]Status: DisposedITAT Jaipur30 Dec 2024AY 2011-12
Section 142(1)Section 143(3)Section 144Section 153A

…evant extract of the submissions filed by the assessee, which are identical for both assessment years on the legal issue, along with the contentions raised, is set out hereunder: “1.4 In the case of Central Bureau of Investigation v. V. C. Shukla & Ors. 1998 3 SCC 410 popularly known as Jain Hawala Case where Section 34 of the Evidence Act, 1872 has been explained. In this case it is held that entries in Jain Notebooks held on facts admissible under Section 34, but file containing loose sheets of papers are not "book" and hence entries therein not admissible under Section 34. Further it was also held in this cas…

Siyaram Exports India Pvt. Ltd., Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 440/JPR/2018[2013-14]Status: DisposedITAT Jaipur30 Dec 2024AY 2013-14
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

…evant extract of the submissions filed by the assessee, which are identical for both assessment years on the legal issue, along with the contentions raised, is set out hereunder: “1.4 In the case of Central Bureau of Investigation v. V. C. Shukla & Ors. 1998 3 SCC 410 popularly known as Jain Hawala Case where Section 34 of the Evidence Act, 1872 has been explained. In this case it is held that entries in Jain Notebooks held on facts admissible under Section 34, but file containing loose sheets of papers are not "book" and hence entries therein not admissible under Section 34. Further it was also held in this cas…

Shri Satish Chandra Katta, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

In the result, Ground No. 3 is allowed for statistical purposes

ITA 437/JPR/2018[2011-12]Status: DisposedITAT Jaipur30 Dec 2024AY 2011-12
Section 142(1)Section 143(3)Section 144Section 153A

…levant extract of the submissions filed by the assessee, which are identical for both assessment years on the legal issue, along with the contentions raised, is set out hereunder: “1.4 In the case of Central Bureau of Investigation v. V. C. Shukla & Ors. 1998 3 SCC 410 popularly known as Jain Hawala Case where Section 34 of the Evidence Act, 1872 has been explained. In this case it is held that entries in Jain Notebooks held on facts admissible under Section 34, but file containing loose sheets of papers are not "book" and hence entries therein not admissible under Section 34. Further it was also held in this cas…

Shri Satish Chandra Katta, Jaipur vs. Deputy Commissioner of Income Tax, Jaipur

ITA 436/JPR/2018[2010-11]Status: DisposedITAT Jaipur30 Dec 2024AY 2010-11
For Appellant: Shri Rohan Sogani (C.A.)For Respondent: Shri Arvind Kumar (CIT-DR)
Section 142(1)Section 143(3)Section 144Section 153ASection 50C

…levant extract of the submissions filed by the assessee, which are identical for both assessment years on the legal issue, along with the contentions raised, is set out hereunder: “1.4 In the case of Central Bureau of Investigation v. V. C. Shukla & Ors. 1998 3 SCC 410 popularly known as Jain Hawala Case where Section 34 of the Evidence Act, 1872 has been explained. In this case it is held that entries in Jain Notebooks held on facts admissible under Section 34, but file containing loose sheets of papers are not "book" and hence entries therein not admissible under Section 34. Further it was also held in this cas…

Brij Gopal Construction Company (P) Ltd., New Delhi vs. DCIT Central Circle-3, New Delhi

In the result, appeal filed by the assessee is partly allowed

ITA 2363/DEL/2023[2021-22]Status: DisposedITAT Delhi20 Dec 2024AY 2021-22

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Nimisha Singh, CIT DR
Section 115BSection 132Section 139Section 153ASection 153DSection 69BSection 69C

…erial and evidence. The evidentiary value of loose paper which is unsigned, undated and unverified has been held to be highly questionable and has not been accepted by the Hon’ble Supreme Court and various High Courts in following judgments. CBI vs. VC Shukla 3 SCC 410 (SC) CIT vs. GirishChaudhary (2008) 296 ITR 619 (Delhi) CIT vs. Anil Bhalla (2010) 322 ITR 191 (Delhi) CIT vs. Atam Valves (P.) Ltd. 184 Taxman 6 (P&H) Atul Kumar Jain vs. DCIT (1999) 64 TTJ (Delhi) 786 15. In the case of CIT vs. Jaipal Aggarwal [2013] 212 Taxman 1 (Delhi)- wherein it was held that Dumb documents seized, i.e., from which nothing co…

Naresh Balyan, New Delhi vs. ACIT, New Delhi

In the result, appeal of the assessee is allowed

ITA 3448/DEL/2023[2017-18]Status: DisposedITAT Delhi18 Dec 2024AY 2017-18

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumar[Assessment Year : 2017-18] Naresh Balyan Vs Acit 125-A, Shyam Park Central Circle-16 Nawada, Uttam Nagar Jhandewalan Ext. New Delhi-110059 Delhi Pan-Adqpb8836L Appellant Respondent Appellant By Shri Jasmeet Singh, Adv. & Shri Pranav Menon, Adv. Respondent By Ms. Baljeet Kaur, Cit Dr Date Of Hearing 25.10.2024 18.12.2024 Date Of Pronouncement

Section 132Section 143(1)Section 143(2)Section 153ASection 250(6)Section 292CSection 69ASection 69C

…raf vs CIT 1990 SCC Online All 825; [d] CIT, Delhi (Central)-II vs D.K.Gupta [ITA No.1126/2008] vide order dated 26.09.2008 (Delhi High Court); [e] Neeraj Goel vs ACIT 2019 SCC Online ITAT 66 vide order dated 28.02.2019; [f] CCBI vs V.C.Shukla and Ors. (1998) 3 SCC 410; and [g] Common Cause and Ors. Vs Union of India and Ors. (2017) 11 SCC 731. 9.3 Based on the elucidation of Legal position by the judicial dicta, the Ld. Counsel for the assessee contended that the statutory presumption contemplated u/s 132(4A) r.w.s. 292C of the Act are not absolute but rebuttable. Such presumptions are not available to Naresh Ba…

Sakthi Realty Holdings Pvt. Ltd., Coimbatore vs. DCIT, CC-2, Coimbatore

The appeal stand allowed in terms of our above order

ITA 1163/CHNY/2024[2016-17]Status: DisposedITAT Chennai10 Dec 2024AY 2016-17

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1163/Chny/2024 (िनधा)रण वष) / Assessment Year: 2016-17) M/S Sakthi Realty Holdings Ltd. Dcit बनाम/ #62, Dr. Nanjappa Road, Central Circle-2, Vs. Coimbatore-641 018. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeca-8414-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 20-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R

For Appellant: Shri R. Venkata Raman (CA) - Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR
Section 132Section 153ASection 153D

…e form, not shown to form part of the books of accounts regularly maintained by the assessee or his business entities, do not constitute material evidence. The Hon’ble Court referred to the decision of Hon’ble Supreme Court in the case of CBI vs. V.C. Shukla (3 SCC 410) as well as another decision in Common Cause vs. UOI (supra) while arriving at such a conclusion. The Hon’ble Supreme Court in the case of CBI vs. V.C. Shukla (3 SCC 410) held that every transaction as recorded in the regular books needs to be independently corroborated and proved when some liability is to be fastened in respect of such transaction…

Sakthi Realty Holdings Pvt. Ltd., Coimbatore vs. DCIT, CC-2, Coimbatore

The appeal stand allowed in terms of our above order

ITA 1160/CHNY/2024[2013-14]Status: DisposedITAT Chennai10 Dec 2024AY 2013-14

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1160/Chny/2024 (िनधा)रण वष) / Assessment Year: 2013-14) M/S. Sakthi Realty Holdings Ltd. Dcit बनाम/ #62, Dr. Nanjappa Road, Central Circle-2, Vs. Coimbatore-641 018. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaeca-8414-H (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman(Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 20-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R

For Appellant: Shri R. Venkata Raman(CA) - Ld.ARFor Respondent: Shri R. Clement Ramesh Kumar (CIT) -Ld. DR
Section 132Section 153ASection 153D

…e form, not shown to form part of the books of accounts regularly maintained by the assessee or his business entities, do not constitute material evidence. The Hon’ble Court referred to the decision of Hon’ble Supreme Court in the case of CBI vs. V.C. Shukla (3 SCC 410) as well as another decision in Common Cause vs. UOI (supra) while arriving at such a conclusion. The Hon’ble Supreme Court in the case of CBI vs. V.C. Shukla (3 SCC 410) held that every transaction as recorded in the regular books needs to be independently corroborated and proved when some liability is to be fastened in respect of such transaction…

DCIT CC - 6(1), Mumbai vs. Shri Naresh Bhavanji Chheda, Mumbai

ITA 2999/MUM/2024[2021-22]Status: DisposedITAT Mumbai05 Dec 2024AY 2021-22

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Sanjay Kapadia &For Respondent: Shri S. Srinivasu, CIT-DR &
Section 132Section 69A

…, the Hon'ble Courts have held that such noting/entries are not sufficient evidence and additions cannot be made solely on the said basis. For this proposition, the Ld CIT(A) has placed reliance on the following case laws:- (i) CBI vs. V C Shukla & Ors (1998)(3 SCC 410)(SC) (ii) Common Cause v UOI (2017)(394 ITR 220)(SC) (iii) T.S.Venkatesan vs. Asst. CIT (2000)(74 ITD 298)(Cal) (iv) Harmohinder Kaur vs. DCIT (2021)(124 taxmann.com 68)(Amrt Trib) 5. The Ld.CIT(A) summarized his views as under and accordingly deleted the three additions mentioned above:- “14.6 Thus it is seen that the Hon'ble Courts have clearly h…

Naresh Bhavanji Chheda, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle 6(1), Mumbai

The appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 2607/MUM/2024[2021-22]Status: DisposedITAT Mumbai05 Dec 2024AY 2021-22

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan

For Appellant: Shri Sanjay Kapadia &For Respondent: Shri S. Srinivasu, CIT-DR &
Section 132Section 69A

…, the Hon‟ble Courts have held that such noting/entries are not sufficient evidence and additions cannot be made solely on the said basis. For this proposition, the Ld CIT(A) has placed reliance on the following case laws:- (i) CBI vs. V C Shukla & Ors (1998)(3 SCC 410)(SC) (ii) Common Cause v UOI (2017)(394 ITR 220)(SC) (iii) T.S.Venkatesan vs. Asst. CIT (2000)(74 ITD 298)(Cal) (iv) Harmohinder Kaur vs. DCIT (2021)(124 taxmann.com 68)(Amrt Trib) 5. The Ld.CIT(A) summarized his views as under and accordingly deleted the three additions mentioned above:- “14.6 Thus it is seen that the Hon'ble Courts have clearly h…

Assistant Commissioner of Income Tax, Central Circle, Kota vs. Banas Builders and Developers LLP, Jhalawar

In the result the appeal of the revenue in ITA no

ITA 269/JPR/2024[2018-19]Status: DisposedITAT Jaipur03 Dec 2024AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajendra Jain (Adv.) (V.C)For Respondent: Smt. Alka Gautam, CIT-DR (V.H)
Section 153ASection 250Section 69B

…d Tribunal Co-ordinate Bench in the decision of Nishan Constructions vs. ACIT ITA No. 1502/Ahd/2015; after considering the Hon’ble Apex Court’s landmark decisions in Common Cause vs. Union of India (2017) 77 taxmann.com 245 (SC) and CBI vs. V.C. Shukla (1998) 3 SCC 410 (SC) held that such loose sheets deserves to be treated as a dumb documents only since not revealing full details about the dates containing lack of further particulars and therefore, ought not to be made basis of an addition. Therefore, the impugned addition of on-money payment made in both these assessees’ hands on the basis of a mere dumb docume…