Society v. UOI

394 ITR 220Supreme Court of India2017#141 most cited

What is Society v. UOI authority for?

Uncorroborated loose papers or documents found during a search operation have no evidentiary value and cannot be the sole basis for determining undisclosed income. Additions based on such material require independent evidence to establish trustworthiness and a direct link to the assessee.

493

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2018 to 2026.

Also referred to as

Society v. UOI · Common Cause (a registered society) 394 ITR 220 · loose papers evidentiary value · uncorroborated documents search · independent corroboration undisclosed income · Section 132(4) statement · Section 292C · Section 34 Evidence Act

Sections most often in play

Section 132Section 132(4)Section 153ASection 153CSection 143(3)Section 292CSection 132(4A)Section 69A

Issues it is cited on

section 292ccsection 132(4a)dumb documentssection 34retraction of statementsection 292cloose papersretracted statementsection 153c(1)statement under section 132(4)protective assessmentsection 131(1a)

Judgments citing Society v. UOI

Zaveri Exports Private Limited, Hyderabad vs. ACIT., Central Circle-3(4), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 452/HYD/2024[2018-19]Status: DisposedITAT Hyderabad12 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2018-19 Zaveri Exports Private Limited, Vs. The Acit, Central Circle – 3(4), Hyderabad. Hyderabad. Pan : Aaacz1286A. (Appellant) (Respondent) Assessee By: Shri H. Srinivasulu, Advocate. Revenue By: Ms. T. Vijaya Lakshmi, Cit-Dr Date Of Hearing: 09.07.2024 Date Of Pronouncement: 12.07.2024

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: Ms. T. Vijaya Lakshmi, CIT-DR
Section 132Section 132(4)Section 142(1)Section 143(3)Section 153ASection 263Section 292CSection 38Section 65BSection 68

…to notice the findings of Ld. AO at Para 2.8 of the assessment order dated 19-06-2021 and Ld. AO rightly carne to the view that section 68 is not applicable based Ori the ratio laid down by the Apex Court in the Common clause (A Registered society) and others 394 ITR 220 10, The Ld. PC[T Hyderabad, failed to appreciate that the assessee declared a net profit at 3% on the sales advances of Rs 2,78,17,040/- in the return of Income. 11. The Ld PCIT (Central), Hyderabad, erred in retying on the Statement of Sri Sunil Kumar Tayal as he was under mental tension and stated that the names found in Page No. 79 the unsecu…

Mohammed Ibrabim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangaluru

In the result, appeal of the assessee in ITA

ITA 486/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…ged payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 4.8 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Mohammed Ibrahim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeal of the assessee in ITA

ITA 466/BANG/2024[2017-18]Status: DisposedITAT Bangalore08 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…ged payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 4.8 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Mohammed Ibrahim Mohideen, Kerala vs. Assistant Commissioner of Income-Tax, Central Circle-2, Mangalore

ITA 465/BANG/2024[2016-17]Status: DisposedITAT Bangalore08 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 153ASection 69B

…eged payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 4.8 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Mohammed Ibrahim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeal of the assessee in ITA

ITA 464/BANG/2024[2015-16]Status: DisposedITAT Bangalore08 Jul 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…ged payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 4.8 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Mohammed Ibrahim Mohideen, Kerala vs. Asst. Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeal of the assessee in ITA

ITA 463/BANG/2024[2014-15]Status: DisposedITAT Bangalore08 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 153ASection 69B

…ged payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 4.8 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

M/S. Emirates Hindustan Builders and Developers, Kerala vs. Assistant Commissioner of Income-Tax, Central Circle-2, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 415/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Guru Kumar S., D.R
Section 132(4)Section 143(3)Section 148Section 68

…ed payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 15.6 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Mkh Infrastructure, Kerala vs. Deputy Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 174/BANG/2024[2017-18]Status: DisposedITAT Bangalore08 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Guru Kumar S., D.R
Section 132(4)Section 143(3)Section 148Section 68

…ed payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 15.6 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-1, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 271/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…upon to frame the assessment orders. The observation of AO would mean that the AO has acknowledged that the seized material as non-speaking documents. He relied on the decision of the Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI ['2017] 394 ITR 220 (SC) for the proposition that unsigned loose slips cannot be acted upon so as to sustain addition. He further submitted that the Tribunal in the case of Atul Kumar Jain v. DCIT [19991 64 TTJ (Delhi) 786 construed the meaning of the expression "document" in the context of section 132 of the Act as under:- "6.4 The Assessing Officer has made oat th…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-1, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 270/BANG/2024[2017-18]Status: DisposedITAT Bangalore04 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…upon to frame the assessment orders. The observation of AO would mean that the AO has acknowledged that the seized material as non-speaking documents. He relied on the decision of the Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI ['2017] 394 ITR 220 (SC) for the proposition that unsigned loose slips cannot be acted upon so as to sustain addition. He further submitted that the Tribunal in the case of Atul Kumar Jain v. DCIT [19991 64 TTJ (Delhi) 786 construed the meaning of the expression "document" in the context of section 132 of the Act as under:- "6.4 The Assessing Officer has made oat th…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-1, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 269/BANG/2024[2016-17]Status: DisposedITAT Bangalore04 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…upon to frame the assessment orders. The observation of AO would mean that the AO has acknowledged that the seized material as non-speaking documents. He relied on the decision of the Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI ['2017] 394 ITR 220 (SC) for the proposition that unsigned loose slips cannot be acted upon so as to sustain addition. He further submitted that the Tribunal in the case of Atul Kumar Jain v. DCIT [19991 64 TTJ (Delhi) 786 construed the meaning of the expression "document" in the context of section 132 of the Act as under:- "6.4 The Assessing Officer has made oat th…

M/S. Hindusthan Bawa Builders, Mangalore vs. Assistant Commissioner of Income Tax, Central Circle-2, Mangalore

In the result, appeals of the assessee in ITA Nos

ITA 268/BANG/2024[2014-15]Status: DisposedITAT Bangalore04 Jul 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 153CSection 69B

…upon to frame the assessment orders. The observation of AO would mean that the AO has acknowledged that the seized material as non-speaking documents. He relied on the decision of the Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI ['2017] 394 ITR 220 (SC) for the proposition that unsigned loose slips cannot be acted upon so as to sustain addition. He further submitted that the Tribunal in the case of Atul Kumar Jain v. DCIT [19991 64 TTJ (Delhi) 786 construed the meaning of the expression "document" in the context of section 132 of the Act as under:- "6.4 The Assessing Officer has made oat th…

DCIT (Central), Bhopal vs. Shailendra Sharma, Bhopal

In the result the appeals of the assessee for the Assessment

ITA 305/IND/2023[2015-16]Status: DisposedITAT Indore24 Jun 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 142(1)Section 153A

…to 9 as under: “6. The Tribunal has considered the aforesaid judgment while dismissing the appeal of the Revenue. The Apex Court in the case of Common Cause (A Registered Society) v. Union of India reported in (2017) 30 ITJ 197 (SC) (2017) 16 STD 132: (2017) 394 ITR 220 (2017) 245 Тахтап 214: (2017) 77 taxmann.com 245, 22, 24 and 27 has held as under :- 22. In case of Sahara, in addition we have the adjudication by the Income Tax Settlement Commission. The order has been placed on record along with L.A. No. 4. The Settlement Commission has observed that the scrutiny of entries on loose papers, computer prints, h…

Income Tax Officer W 1, Hassan vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1166/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…d payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 13.22 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Income Tax Officer, W-1, Vijayanagar vs. Ramachandra Setty and Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1165/BANG/2023[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…d payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 13.22 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Income Tax Officer Ward-1 Hassan, Hassan vs. Ramachandra Setty and Songs, Hassan

In the result, appeal of the assessee in ITA

ITA 1164/BANG/2023[2014-15]Status: DisposedITAT Bangalore10 Jun 2024AY 2014-15

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…d payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 13.22 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Income Tax Officer, W-1, Hassan vs. Ramachandra Setty & Sons, Hassan

In the result, appeal of the assessee in ITA

ITA 1163/BANG/2023[2013-14]Status: DisposedITAT Bangalore10 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…d payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 13.22 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

M/S. S. Ramashandra Setty & Sons, Hassan vs. Income Tax Officer, Ward-1, Hassan

In the result, appeal of the assessee in ITA

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115BSection 132(4)Section 250Section 69B

…d payment made simply on the basis of uncorroborated noting and scribbling on loose sheets made by some person have no evidentiary value and is unsustainable and bad in law. 13.22 The Hon'ble Supreme Court in Common Cause (A Registered Society) v. UOI [2017] 394 ITR 220 (SC) observed with regard to evidentiary value that entries in books of account are not by themselves sufficient to charge any person with liability, the reason being that a man cannot be allowed to make evidence for himself by what he chooses to write in his own books behind the back of the parties. There must be independent evidence of the tran…

Shri K. Palaniswami, Salem vs. DCIT, Central Circle-2(2), Chennai

The appeals of the revenue stand dismissed

ITA 215/CHNY/2023[2017-18]Status: DisposedITAT Chennai03 Apr 2024AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.125/Chny/2023 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.126/Chny/2023 (िनधा"रण वष" / Assessment Year: 2016-17) & 3. आयकरअपील सं./ Ita No.127/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) Dcit Shri Karuppagounder Palaniswami बनाम 171/1B, Rajapuram 1St Street, Central Circle-2(2) / Vs. Chennai. Nedunchalai Nagar, Salem-636 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ayxpp-6611-P (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. आयकरअपील सं./ Ita No.213/Chny/2023 (िनधा"रण वष" / Assessment Year: 2015-16) & 5. आयकरअपील सं./ Ita No.214/Chny/2023 (िनधा"रण वष" / Assessment Year: 2016-17) & 6. आयकरअपील सं./ Ita No.215/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) बनाम/ Shri Karuppagounder Palaniswami Dcit 171/1B, Rajapuram 1St Street, Vs. Central Circle-2(2) Nedunchalai Nagar, Salem-636 004. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ayxpp-6611-P ((अपीलाथ"/Appellant)) : (!"थ" / Respondent)

For Appellant: Shri Sushil Kumar (Advocate) - Ld. ARFor Respondent: Shri V. Nandakumar (CIT) - Ld. DR
Section 132(4)Section 143(3)

…withdrawn. 4.4 However, Ld. AO continued to allege that the payments were made to various persons including the assessee, the then Highway Minster (represented by the abbreviation HM). The decision of Hon’ble Supreme Court in the case of Common cause V/s UOI (394 ITR 220), as relied upon by the assessee, was held to be distinguishable. The Ld. AO also held that the denial by the assessee was not backed by any logic or evidence. In the present case, the entries in the seized material were in the form of proper accounts, maintained systematically on daily basis with tick-marks showing that the entries were verified…

Shri K. Palaniswami, Salem vs. DCIT, Central Circle-2(2), Chennai

The appeals of the revenue stand dismissed

ITA 214/CHNY/2023[2016-17]Status: DisposedITAT Chennai03 Apr 2024AY 2016-17

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं./ Ita No.125/Chny/2023 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.126/Chny/2023 (िनधा"रण वष" / Assessment Year: 2016-17) & 3. आयकरअपील सं./ Ita No.127/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) Dcit Shri Karuppagounder Palaniswami बनाम 171/1B, Rajapuram 1St Street, Central Circle-2(2) / Vs. Chennai. Nedunchalai Nagar, Salem-636 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ayxpp-6611-P (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. आयकरअपील सं./ Ita No.213/Chny/2023 (िनधा"रण वष" / Assessment Year: 2015-16) & 5. आयकरअपील सं./ Ita No.214/Chny/2023 (िनधा"रण वष" / Assessment Year: 2016-17) & 6. आयकरअपील सं./ Ita No.215/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) बनाम/ Shri Karuppagounder Palaniswami Dcit 171/1B, Rajapuram 1St Street, Vs. Central Circle-2(2) Nedunchalai Nagar, Salem-636 004. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Ayxpp-6611-P ((अपीलाथ"/Appellant)) : (!"थ" / Respondent)

For Appellant: Shri Sushil Kumar (Advocate) - Ld. ARFor Respondent: Shri V. Nandakumar (CIT) - Ld. DR
Section 132(4)Section 143(3)

…withdrawn. 4.4 However, Ld. AO continued to allege that the payments were made to various persons including the assessee, the then Highway Minster (represented by the abbreviation HM). The decision of Hon’ble Supreme Court in the case of Common cause V/s UOI (394 ITR 220), as relied upon by the assessee, was held to be distinguishable. The Ld. AO also held that the denial by the assessee was not backed by any logic or evidence. In the present case, the entries in the seized material were in the form of proper accounts, maintained systematically on daily basis with tick-marks showing that the entries were verified…