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“incriminating material”

Search & SeizureSection 153ASection 153A8,981 judgments

The decision most relied on for incriminating material is CIT v. Kabul Chawla (380 ITR 573), cited in 3,235 judgments on BharatTax.

Leading authorities on incriminating material

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

CIT v. Sinhgad Technical Education Society
397 ITR 344 · 2017 · Supreme Court
1,589
citing judgments

For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.

Pr. CIT v. Meeta Gutgutia
395 ITR 526 · 2017 · High Court
1,226
citing judgments

In search assessments under Section 153A, additions to income are permissible only if incriminating material is found during the search; in the absence of such material, completed assessments cannot be disturbed. A statement recorded under Section 132(4) and later retracted may not, on its own, constitute sufficient incriminating evidence for making additions.

All Cargo Global Logistics Ltd. v. DCIT
137 ITD 287 · 2012 · ITAT
907
citing judgments

In non-abated assessments, the Assessing Officer can make additions under section 153A based on books of accounts or documents found during a search but not produced during the original assessment, provided such material is incriminating.

PCIT v. Best Infrastructure (India) (P.) Ltd.
397 ITR 82 · 2017 · High Court
786
citing judgments

A statement recorded under Section 132(4) of the Income Tax Act, 1961, does not by itself constitute incriminating material for making additions to income.

CIT v. RRJ Securities Ltd.
380 ITR 612 · 2016 · High Court
689
citing judgments

Completed assessments can be interfered with under Section 153A or 153C only on the basis of incriminating material unearthed during the search, necessitating a direct correlation between the discovered material and the power to assess or reopen concluded assessments.

Pr. CIT v. Saumya Constructions (P.)Ltd.
387 ITR 529 · 2016 · High Court
670
citing judgments

Assessments under Section 153A cannot be sustained without any incriminating material found during the search that substantiates the additions. This principle applies even to completed assessments where no additional income is disclosed.

Judgments citing incriminating material

Akash Kapoor, Haryana vs. Deputy Commissioner of Income Tax, Central Circle - 7, New Delhi

Appeal is partly allowed in above terms

ITA 766/DEL/2025[2018-19]Status: DisposedITAT Delhi29 Oct 2025AY 2018-19
Section 132Section 139(1)Section 139(4)Section 142(1)Section 143(1)Section 143(2)Section 153ASection 69ASection 80T

conducted; secondly, discovery of documents found in the custody of the ‘searched person’ relating to the ‘other person’; and thirdly, the incriminating material to invoke proceedings against the ‘other person’. 4.4.1. Learned counsel also submits that clearly the present petitioner does not fall within the term ‘other person’, and thus ... Assessment Year 2019-20 issued on 16.06.2023 and the assessment proceedings initiated thereupon cannot be quashed, only on the ground that there is no incriminating material found or seized during the search and seizure in question. 5.4. Learned counsel further submits that the impugned notice dated 16.06.2023 had been issued

Anoop Jain HUF, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4043/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

search) and the settled position of law that categorically requires additions for unabated assessment years to be made solely on the basis of "incriminating material" unearthed during the course of the Assessee's search. 3. That the Ld. A.O and the Ld. CIT(A) have erred in ignoring the mandate ... assessee has challenged the action of AO in assuming jurisdiction and making additions in the order passed u/s 153A without referring to any incriminating material found and seized as a result of the search from the possession of the assessee. 8. The facts leading to these grounds of appeal

Anoop Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), Central Circle - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4042/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

search) and the settled position of law that categorically requires additions for unabated assessment years to be made solely on the basis of "incriminating material" unearthed during the course of the Assessee's search. 3. That the Ld. A.O and the Ld. CIT(A) have erred in ignoring the mandate ... assessee has challenged the action of AO in assuming jurisdiction and making additions in the order passed u/s 153A without referring to any incriminating material found and seized as a result of the search from the possession of the assessee. 8. The facts leading to these grounds of appeal

Ritu Jain, Delhi vs. Joint Commissioner of Income Tax (OSD), CC - 1, Noida

In the result, appeal of the assessee is allowed

ITA 4038/DEL/2025[2013-14]Status: DisposedITAT Delhi29 Oct 2025AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2013-14] Ritu Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1 Market, New Delhi-110001 Noida Pan-Aampj9586C Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aadpj2136K Appellant Respondent [Assessment Year : 2013-14] Anoop Jain Huf Vs Jcit (Osd) No.11, Barbar Lane, Bengali Central Circle-1, Market, New Delhi-110001 Noida Pan-Aaaha6321A Appellant Respondent Appellant By Shri S.K.Tulsian, Adv. & Shri Bhoomija Verma, Adv. Respondent By Shri Mahes Kumar, Cit Dr Date Of Hearing 03.09.2025 Date Of Pronouncement 29.10.2025 Order

Section 115BSection 127Section 132Section 139Section 142Section 142(1)Section 142(2)Section 142(3)Section 143(2)Section 153A

search) and the settled position of law that categorically requires additions for unabated assessment years to be made solely on the basis of "incriminating material" unearthed during the course of the Assessee's search. 3. That the Ld. A.O and the Ld. CIT(A) have erred in ignoring the mandate ... assessee has challenged the action of AO in assuming jurisdiction and making additions in the order passed u/s 153A without referring to any incriminating material found and seized as a result of the search from the possession of the assessee. 8. The facts leading to these grounds of appeal

Harmit Bawa, Delhi vs. Central Circle-27, Dy, Commissioner of Income Tax, New Delhi, Delhi

The appeals are allowed

ITA 3345/DEL/2025[2015-2016]Status: DisposedITAT Delhi29 Oct 2025AY 2015-2016

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Rajendra Singh Rathore, Adv. &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153C

said search for which proceedings u/s 153C of the Act were initiated. Though the case of the assessee is that there were no incriminating material, but, otherwise what is relevant is that notice u/s 153C of the Act was issued on 06.08.2022 in response to which the assessee filed return

Harmit Bawa, Delhi vs. Central Circle 27, Delhi, Assistant Commissioner of Income Tax

The appeals are allowed

ITA 3326/DEL/2025[2014-2015]Status: DisposedITAT Delhi29 Oct 2025AY 2014-2015

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Rajendra Singh Rathore, Adv. &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 153C

said search for which proceedings u/s 153C of the Act were initiated. Though the case of the assessee is that there were no incriminating material, but, otherwise what is relevant is that notice u/s 153C of the Act was issued on 06.08.2022 in response to which the assessee filed return

ACIT, New Delhi vs. Vrinda Farms Private Limited, New Delhi

In the result, the appeal of the Revenue as well as cross objections of the assessee are dismissed

ITA 4849/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Acit, Central Circle 4, Vs. Vrinda Farms Private Limited, New Delhi. 43, Community Centre, Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) Co Nos.13 & 19/Del/2025 (In Ita No.4849/Del/2024) (Assessment Year: 2016-17) Vrinda Farms Private Limited, Vs. Acit, Central Circle 4, 43, Community Centre, New Delhi. Bhageria House, Zakir Nagar, New Friends Colony, New Delhi – 110 025. (Pan : Aaacv0355L) (Appellant) (Respondent) Assessee By : Shri Biren Shah, Ca Revenue By : Shri Dheeraj Kumar Jain, Sr. Dr Date Of Hearing : 02.09.2025 Date Of Order : 29.10.2025 Order Per S.Rifaur Rahman: 1. This Appeal Is Filed By The Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-23, New Delhi [“Ld. Cit(A)”, For Short]

For Appellant: Shri Biren Shah, CAFor Respondent: Shri Dheeraj Kumar Jain, Sr. DR
Section 132(4)Section 133(6)Section 68

used in section 132(4) of the Act cannot be treated as "as evidence" when statement u/s 132(4) made while con fronting with incriminating material gathered during the search operations. 7. Ld. CIT(A) has erred in holding that the Assessing Officer should have conducted further enquiry to find

Suryavanshi Finlease Private Limited, Delhi vs. ACIT, Central Circle, Karnal

The appeal is allowed

ITA 2900/DEL/2024[2009-10]Status: DisposedITAT Delhi29 Oct 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Krinwant Sahayassessment Year : 2009-10 Suryavanshi Finlease Private Ltd., Vs. Acit, C-5/2A, Rana Pratap Bagh, Central Circle, Opp. Cc Colony, Karnal. New Delhi – 110 085. Pan: Aabcs1933N Assessee By : Shri Ved Jain, Advocate; Shri Pawan Garg, Ca & Shri Ishika Dua, Ca Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 25.09.2025 Date Of Pronouncement : 29.10.2025

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 153Section 153A

assessment order passed section 153A of the Act, being bad in law as the same has been passed in the absence of any incriminating material found during the course of search. 4. As per ld. Counsel, in this case, AO has initiated the assessment proceedings invoking 4th proviso to section

Sapphire Reclaim Rubber Private Limited, Shapar, Rajkot vs. The Principal Commissioner of Income Tax -1, Rajkot

In the result, appeal filed by the Assessee is rejected

ITA 272/RJT/2024[2014-15]Status: DisposedITAT Rajkot28 Oct 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 272/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Sapphire Reclaim Rubber Pvt. Ltd. Vs. The Principal Commissioner Of Bhoomi Industrial Area, Plot No: Income Tax-1, 2Nd Floor Aayakar Bhawan, Race 1/44, National Highway 27, Veraval (Shapar), Course Ring Road, Rajkot - 360311 Rajkot Gujarat - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aapcs6205B (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 30/07/2025 Date Of Pronouncement : 28/10/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. Sr. (DR)
Section 115BSection 132Section 133ASection 147Section 148Section 263Section 69A

Enterprise. Considering the denial of the appellant, the AO issued a letter to the Jurisdictional Assessing Officer (AO) on 01.09.2021 and 14.09.2021 demanding relevant incriminating materials on the basis of which the case of the appellant was reopened. The above facts are in the order sheet of the ITBA portal ... again denied having entered into any transaction with Shri Chetan Bhalodiya. Prop. of M/s Yash Enterprise. The appellant requested for a copy of the incriminating material available on record and requested for a cross examination of Sapphire Reclaim Rubber Pvt. Ltd Shri Chetan Bhalodiya. The AO did not have

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

The appeal of the revenue is dismissed

ITA 1557/KOL/2025[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 131Section 133ASection 143(3)Section 195Section 250Section 40Section 68

High Court in the case of “Naresh Kumar Agarwal” (2015) 53 taxmann.com 306 (Andhra Pradesh) has observed that where, in the absence of any incriminating material etc. found from the premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have ... income was also deposited, but thereafter it was contended by the assessee that the surrender was made under threat or coercion and that no incriminating material was Vivek Gupta; AY 2013-14 & 2014-15 found during the search action. The stand of the department was that the admission was voluntary

Deputy Commssioner of Income Tax, Central Circle, 4(3), Kolkata vs. Privi Exports Private Limited, Kolkata

Accordingly the ground No. 2 is dismissed by upholding the order of Ld

ITA 1456/KOL/2025[2017-18]Status: DisposedITAT Kolkata28 Oct 2025AY 2017-18

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 131Section 133ASection 250Section 68

High Court in the case of “Naresh Kumar Agarwal” (2015) 53 taxmann.com 306 (Andhra Pradesh) has observed that where, in the absence of any incriminating material etc. found from the premises of the assessee during the course of search, statement of assessee recorded under section 132(4) would not have ... income was also deposited, but thereafter it was contended by the assessee that the surrender was made under threat or coercion and that no incriminating material was found during the search action. The stand of the department was that the admission was voluntary and was not under a mistaken belief

DCIT Central Circle 1 4 Kolkata, Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2245/KOL/2024[2016-17]Status: DisposedITAT Kolkata28 Oct 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

notices issued u/s 133(6) of the Act. The ld. CIT (A) noted that the ld. AO has not referred to any incriminating material seized in the course of survey on the basis of which assessment was reopened. The ld. CIT (A) in Para no.6.12(4) of the Act noted ... cash loans taken by the assessee during the year. 030. The facts in brief are that the ld. AO observed on the basis of incriminating material found during the course of survey which was also extracted by the ld. AO in para no.13.3.1. of the assessment order that assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2196/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Oct 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

notices issued u/s 133(6) of the Act. The ld. CIT (A) noted that the ld. AO has not referred to any incriminating material seized in the course of survey on the basis of which assessment was reopened. The ld. CIT (A) in Para no.6.12(4) of the Act noted ... cash loans taken by the assessee during the year. 030. The facts in brief are that the ld. AO observed on the basis of incriminating material found during the course of survey which was also extracted by the ld. AO in para no.13.3.1. of the assessment order that assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2187/KOL/2024[2015-16]Status: DisposedITAT Kolkata28 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

notices issued u/s 133(6) of the Act. The ld. CIT (A) noted that the ld. AO has not referred to any incriminating material seized in the course of survey on the basis of which assessment was reopened. The ld. CIT (A) in Para no.6.12(4) of the Act noted ... cash loans taken by the assessee during the year. 030. The facts in brief are that the ld. AO observed on the basis of incriminating material found during the course of survey which was also extracted by the ld. AO in para no.13.3.1. of the assessment order that assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Limited, Kolkata

In the result, the appeals of the Revenue are dismissed and the COs of the assessee are partly allowed

ITA 2179/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

notices issued u/s 133(6) of the Act. The ld. CIT (A) noted that the ld. AO has not referred to any incriminating material seized in the course of survey on the basis of which assessment was reopened. The ld. CIT (A) in Para no.6.12(4) of the Act noted ... cash loans taken by the assessee during the year. 030. The facts in brief are that the ld. AO observed on the basis of incriminating material found during the course of survey which was also extracted by the ld. AO in para no.13.3.1. of the assessment order that assessee

DCIT, Central Circle-1(4), Kolkata vs. Murlidhar Ratanlal Exports Ltd., Kolkata

In the result, the appeals of the Revenue are dismissed and the

ITA 2178/KOL/2024[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri A.K. Tulsyan &For Respondent: Shri Sallong Yaden, DR
Section 133ASection 139(1)Section 143(2)Section 143(3)Section 147Section 148

notices issued u/s 133(6) of the Act. The Id. CIT (A) noted that the Id. AO has not referred to any incriminating material seized in the course of survey on the basis of which assessment was reopened. The Id. CIT (A) in Para no.6.12(4) of the Act noted ... cash loans taken by the assessee during the year. 030. The facts in brief are that the Id. AO observed on the basis of incriminating material found during the course of survey which was also extracted by the Id. AO in para no.13.3.1. of the assessment order that assessee

DCIT, Central Circle-8(1), Mumbai vs. Ei Resorts & Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3926/MUM/2025[2020-21]Status: DisposedITAT Mumbai28 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

erred in not considering that the excel sheet seized from computer of Shri Tarun NandkumarSeksaria was the incriminating material containing the detailed bifurcation of the amounts paid in cheque for acquisition of land at Kolgaon (Column 'A') and amounts paid in cash for acquiring the said land at Kolgaon (Column

DCIT, Central Circle-8(1), Mumbai vs. E I Resorts and Clubs Pvt Ltd, Mumbai

3213/Mum/2025

ITA 3886/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 132Section 132(4)Section 69A

erred in not considering that the excel sheet seized from computer of Shri Tarun NandkumarSeksaria was the incriminating material containing the detailed bifurcation of the amounts paid in cheque for acquisition of land at Kolgaon (Column 'A') and amounts paid in cash for acquiring the said land at Kolgaon (Column

Shri Dilip J Thakkar, Mumbai vs. DCIT, Central Circle -6(4), Mumbai

In the result, the appeal filed by the assessee stands allowed

ITA 37/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Arun Khodpia ()

Section 131

contrary, the Ld.DR submitted as under: • During the search on the assessee u/s 132 of the Act on 10- 08-2011, several incriminating material were unearthed relating to the role of the assessee and his wife in the Chagganlal Suchak Family Trust (CSFT) and operation of eight bank accounts held

Ei Resorts and Clubs Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -8(1), Mumbai

3213/Mum/2025

ITA 3213/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Oct 2025AY 2012-13
Section 132Section 132(4)Section 69A

erred in not considering that the excel sheet seized from computer of Shri Tarun NandkumarSeksaria was the incriminating material containing the detailed bifurcation of the amounts paid in cheque for acquisition of land at Kolgaon (Column 'A') and amounts paid in cash for acquiring the said land at Kolgaon (Column