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“loose papers”

Search & SeizureSection 132Section 1322,159 judgments

The decision most relied on for loose papers is Society v. UOI (394 ITR 220), cited in 493 judgments on BharatTax.

Leading authorities on loose papers

394 ITR 220 · 2017 · Supreme Court

citing judgments

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.

CBI v. V.C. Shukla

3 SCC 410 · 1998 · Supreme Court

citing judgments

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.

CIT v. Nikunj Exim Enterprises Pvt. Ltd.

372 ITR 619 · 2015 · High Court

citing judgments

Transactions defying human probability cannot be applied to isolated purchases if sales are accepted as genuine, and purchases cannot be disallowed without considering the entire transaction and documentary evidence. Failure to produce parties in an assessment proceeding may not be fatal to the assessee.

DCIT v. Sunil Kumar Sharma

159 Taxmann.com 179 · 2024 · High Court

citing judgments

Loose sheets of paper containing jottings, not shown to be part of regularly maintained books of accounts, do not constitute incriminating material for initiating assessment under section 153C. The satisfaction note required for 153C proceedings must specify the assessment year to which the alleged incriminating material belongs.

Common Cause v. Union of India

77 Taxmann.com 245 · 2017 · Supreme Court

citing judgments

Additions under the Income Tax Act cannot be made solely based on entries in loose sheets, dumb documents, or mere sworn statements without independent, reliable, and cogent corroborating evidence. Uncorroborated loose papers are not admissible evidence on their own, even if the original context was criminal investigation.

CIT v. Girish Chaudhary

296 ITR 619 · 2008 · High Court

citing judgments

Additions to income cannot be made solely based on "dumb documents" or vague loose papers seized during a search that merely indicate rates without specific corroborative material linking them to the assessee's unaccounted transactions. The presumption under Section 292C may not apply to such documents.

Principal Commissioner Income Tax, Central-2 v. Umesh Ishrani

108 Taxmann.com 437 · 2019 · High Court

citing judgments

An addition to income cannot be made solely based on entries in loose papers found during a search without conducting any independent inquiry or verification from the alleged seller or developer. Reliance solely on digital records without corroborative evidence is insufficient for an addition.

CIT v. Maulikkumar K. Shah

307 ITR 137 · 2008 · High Court

citing judgments

Additions on account of on-money receipts cannot be justified solely based on loose papers or 'sauda-chithis' without evidence of actual payment or a clear indication of a completed transaction within those documents.

Judgments citing loose papers

J Kumar Infraprojects Limited, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle -5(1), Mumbai

ITA 4148/MUM/2024[2017-18]Status: DisposedITAT Mumbai03 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

because of unaccounted sale of scrap etc. have been made. 11. Whether the Ld.CIT(A) erred in observing that AO has also referred a loose paper, page -1& 2 of Annexure-A2 at a site office at G Block wherein murrum is 0.1% of running account ignoring the facts ... Assessee Company. During the course of search and seized action u/s.132 of the Act, various incriminating evidences were found in the form of loose papers, diary, whatsapp chats in mobile phones of promoter, director, employees as also digital data in the form of excel sheets, trial balances, etc. maintained

J Kumar Infraprojects Limited, Mumbai vs. The Dy. Commissioner of Income Tax Central Circle -5(1), Mumbai

ITA 4147/MUM/2024[2016-17]Status: DisposedITAT Mumbai03 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 69A

because of unaccounted sale of scrap etc. have been made. 11. Whether the Ld.CIT(A) erred in observing that AO has also referred a loose paper, page -1& 2 of Annexure-A2 at a site office at G Block wherein murrum is 0.1% of running account ignoring the facts ... Assessee Company. During the course of search and seized action u/s.132 of the Act, various incriminating evidences were found in the form of loose papers, diary, whatsapp chats in mobile phones of promoter, director, employees as also digital data in the form of excel sheets, trial balances, etc. maintained

Soham Papers Private Limited, Morbi vs. Pr. CIT, Rajkot-1, Rajkot

ITA 371/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 115BSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

M/S. Dhruv Craft Mill Pvt. Ltd., Morbi vs. The Principal Commissioner of Income Tax-1, Rajkot

ITA 335/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 11SSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Dhruv Print Pack Industries, Morbi vs. Pr. CIT, Rajkot-1, Rajkot

ITA 331/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 11SSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Hetalkumar Pravinchandra Rajyaguru, Rajkot vs. Pr. CIT, Rajkot-1, Rajkot

ITA 329/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Jun 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 11SSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Shamji Nathu Vaishya, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 327/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Jun 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 115BSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Kishor Veljibhai Fofandi, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 326/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 115BSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Deepmala Marine Exports, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 324/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 115BSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Chunilal Govind Vanik, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 323/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 115BSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Sun Exports, Veraval vs. Pr. CIT, Rajkot-1, Rajkot

ITA 322/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

Section 11SSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Bharatkumar Kalyanjibhai Bhindi, Junagadh vs. PCIT, Rajkot-1, Rajkot

ITA 312/RJT/2024[2019-20]Status: DisposedITAT Rajkot30 Jun 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. No. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 324/Rjt/2024 322/Rjt/2024 323/Rjt/2024 312/Rjt/2024 326/Rjt/2024 327/Rjt/2024 329/Rjt/2024 331/Rjt/2024 335/Rjt/2024 371/Rjt/2024

Section 115BSection 143(3)Section 263Section 69A

submitted before the learned PCIT that said disclosure has been made by the partner after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee, the noting ... learned PCIT also noticed that the disclosure has been made by the partner, after examining the noting made in a note book and loose papers found and seized from the office premises of the assessee, during the survey proceedings and as per explanation given by the assessee in his statement

Income Tax Officer-1(1), Indore vs. Anant Steel Private Limited, Indore

ITA 831/IND/2024[2011-12]Status: DisposedITAT Indore30 Jun 2025AY 2011-12

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Deputy Commissioner of Income Tax-6, Kanpur vs. M/S. Habib Tannery Private Limited, Kanpur

In the result, the appeal of the Department stands dismissed

ITA 564/LKW/2018[2015-16]Status: DisposedITAT Lucknow30 Jun 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2015-16 Dy. Commissioner Of Income V. M/S Habib Tannery Pvt. Ltd. Tax-6 15-B, 150 Ft. Road Kanpur Jajmau, Kanpur Tan/Pan:Aach4129E (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri H. S. Usmani, Cit (Dr) O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri H. S. Usmani, CIT (DR)

Section 131Section 133(6)Section 133ASection 142(1)Section 143(3)Section 271(1)(c)

conducted on 18.02.2015 at the premises of the assessee. During the course of survey, various incriminating documents, such as books of account, loose papers, hard disc, ITA No.564/LKW/2018 Page 2 of 21 etc. were found and impounded by the search party. The seized documents included a Diary marked

Ram Mohana Reddy Baddigam, Hyderabad vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 422/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jun 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 153CSection 69A

wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions ... Supreme Court in the case of CIT vs., Sinhgad Technical Education Society [2017] 397 ITR 344 (SC) where it has been clearly held that, loose papers found and seized from the residence of the assessee, an educational institution, indicating capitation fees received by various institutions run by assessee

Ram Mohana Reddy Baddigam, Hyderabad vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 421/HYD/2025[2018-19]Status: DisposedITAT Hyderabad30 Jun 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 153CSection 69A

wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions ... Supreme Court in the case of CIT vs., Sinhgad Technical Education Society [2017] 397 ITR 344 (SC) where it has been clearly held that, loose papers found and seized from the residence of the assessee, an educational institution, indicating capitation fees received by various institutions run by assessee

Ram Mohana Reddy Baddigam, Guntur vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 420/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 153CSection 69A

wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions ... Supreme Court in the case of CIT vs., Sinhgad Technical Education Society [2017] 397 ITR 344 (SC) where it has been clearly held that, loose papers found and seized from the residence of the assessee, an educational institution, indicating capitation fees received by various institutions run by assessee

Ram Mohana Reddy Baddigam, Guntur vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the grounds raised by the assessee are allowed

ITA 419/HYD/2025[2016-17]Status: DisposedITAT Hyderabad30 Jun 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA P. Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 153CSection 69A

wherein the Hon’ble Apex Court held that, investigation could not have been directed on the basis of legally inadmissible evidence in form of ‘loose papers’ and make addition u/sec.69A of the Act. Learned Counsel for the Assessee further relied on the following decisions in support of the above contentions ... Supreme Court in the case of CIT vs., Sinhgad Technical Education Society [2017] 397 ITR 344 (SC) where it has been clearly held that, loose papers found and seized from the residence of the assessee, an educational institution, indicating capitation fees received by various institutions run by assessee

ACIT, Central Circle-4(3), Kolkata vs. Citizen Umbrella Manufacturers Limited, Kolkata

In the result, the appeal of the revenue is dismissed and the cross-objection of the assessee is also dismissed as infructuous

ITA 306/KOL/2025[2020-21]Status: DisposedITAT Kolkata30 Jun 2025AY 2020-21

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 133ASection 139Section 142(1)Section 143(2)Section 143(3)Section 36(1)(va)Section 69A

employed achieving the corresponding undisclosed sales. 5. Contrary to that the ld. A.R supports the impugned order thereby submitting that cash sale found in loose papers was duly credited the cash sale of Rs. 15,57,25,671/- out of total sales ... I.T.A. No. 306/Kol/2025 C.O. No. 34/Kol/2025 Assessment Year: 2020-21 M/s Citizen Umbrella Manufacturers Ltd. examined the cash sales as per loose papers/ memos found with books and found that cash sales in loose paper were duly recorded in the books of account. The operative portion of the order

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kasthoori Raja Dhanush, Chennai

In the result, all the appeals of the Revenue and Cross-Objections

ITA 3192/CHNY/2024[2020-21]Status: DisposedITAT Chennai30 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3188 To 3192/Chny/2024 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 & Cross-Objection Nos.22 To 26/Chny/2025 निर्धारणवर्ष/Assessment Years: 2015-16, 2016-17, 2017-18, 2019-20 & 2020-21 The Acit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement V. : : : : Kasthoori Raja Dhanush, Old No.16/5, New No.33/5, Rajamannar Street, Thyagaraya Nagar, Chennai-600 017. [Pan: Actpv 0618 E] (प्रत्यर्थी/Respondent/Cross- Objector) Mrs. Sheila Parthasarthy, Cit Mr. N. Arjun Raj, Advocate 28.04.2025 30.06.2025 आदेश / Order Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) 19, Chennai (Hereinafter Referred To As `Ld.Cit(A) `) All Dated 17.10.2024 For The

Section 132Section 153ASection 15ASection 271D

well. 7. Briefly stated, the facts relating to the impugned dispute is that, in the course of search upon Shri Anbu, certain loose papers inter alia ID marked ANN/KM/GNA-YOG/LS/S-56 was found & seized from his premises and loose papers document ID marked ANN/PP/RA/LS/S-30 from the premises of his associate, Shri ... monies u/s 69A of the Act. It is observed that, the assessee had objected to the same and contended that mere notings found in loose papers from third party premises cannot be used against him, in absence of any tangible material to corroborate the same. The AO however is found