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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

Society v. UOI
394 ITR 220 · 2017 · Supreme Court
493
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
442
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
391
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
269
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
267
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
175
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
168
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
166
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

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 552/CHNY/2024[2018-19]Status: DisposedITAT Chennai11 Mar 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

entire prosecution based upon such entries which led to the investigation was quashed by this Court." 20. From the above, it is clear that loose papers containing rough scribbling not shown to form part of the books of account regularly maintained by the searched person or its business entities cannot

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 551/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Mar 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

entire prosecution based upon such entries which led to the investigation was quashed by this Court." 20. From the above, it is clear that loose papers containing rough scribbling not shown to form part of the books of account regularly maintained by the searched person or its business entities cannot

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Chennai

In the result, all the five appeals filed by the assessee are allowed

ITA 549/CHNY/2024[2015-16]Status: DisposedITAT Chennai11 Mar 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

entire prosecution based upon such entries which led to the investigation was quashed by this Court." 20. From the above, it is clear that loose papers containing rough scribbling not shown to form part of the books of account regularly maintained by the searched person or its business entities cannot

Mohanraj, Coimbatore vs. DCIT, Central Circle 3, Coimbatore

In the result, all the five appeals filed by the assessee are allowed

ITA 548/CHNY/2024[2014-15]Status: DisposedITAT Chennai11 Mar 2025AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

For Appellant: Mr. S.Sridhar, AdvocateFor Respondent: Ms.T.M.Suganthamala, CIT
Section 153ASection 250Section 56

entire prosecution based upon such entries which led to the investigation was quashed by this Court." 20. From the above, it is clear that loose papers containing rough scribbling not shown to form part of the books of account regularly maintained by the searched person or its business entities cannot

ACIT, Central Circle, Alwar vs. Sh. Tara Chand Gupta, Alwar

In the result the appeal filed by the revenue in ITA no

ITA 514/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA. Nos.447 to 449/JP/2024 निर्धारण वर्ष / Assessment Years : 2015-16 to 2017-18 Shri Tarachand Gupta 9 Keshav Nagar Sch 13, Alwar बनाम ACIT, Vs. Central Circle, Alwar स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AAYPC 5777 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent आयकर अपील सं./ITA. No. 514/JP/2024 निर्धारण वर्ष / Assessment Year : 2017-18 ACIT, Central Circle, Alwar बनाम Shri Tarachand Gupta 9 Kesh

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR a
Section 143(3)Section 68Section 69C

which the Assessee is one of the members. During that search action(s), cash, jewellery, valuables, stock-in-trade, documents, books of account and/or loose papers were found and/or seized from the premises of the members of the Gupta Group of which one such member happens to be the Assessee ... except page -37 (query in this regard raised separately in relevant year) impounded from M/s Gupta Iron Store, assessee’s proprietorship concern. These loose papers were found at the business premise of Gupta Iron store. These are hand written kachi parchis showing various cash transactions relating to their money lending

Sh. Tarachand Gupta, Alwar vs. ACIT, Central Circle, Alwar

In the result the appeal filed by the revenue in ITA no

ITA 449/JPR/2024[2017-18]Status: DisposedITAT Jaipur10 Mar 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA. Nos.447 to 449/JP/2024 निर्धारण वर्ष / Assessment Years : 2015-16 to 2017-18 Shri Tarachand Gupta 9 Keshav Nagar Sch 13, Alwar बनाम Vs. ACIT, Central Circle, Alwar स्थायी लेखा सं./ जीआईआर सं./PAN/GIR No.: AAYPC 5777 E अपीलार्थी / Appellant प्रत्यर्थी / Respondent आयकर अपील सं./ITA. No. 514/JP/2024 निर्धारण वर्ष / Assessment Year : 2017-18 ACIT, Central Circle, Alwar बनाम Shri Tarachand Gupta 9 Ke

For Appellant: Sh. P. C. Parwal, C.AFor Respondent: Sh. Arvind Kumar, CIT-DR a
Section 143(3)Section 68Section 69C

which the Assessee is one of the members. During that search action(s), cash, jewellery, valuables, stock-in-trade, documents, books of account and/or loose papers were found and/or seized from the premises of the members of the Gupta Group of which one such member happens to be the Assessee ... except page -37 (query in this regard raised separately in relevant year) impounded from M/s Gupta Iron Store, assessee’s proprietorship concern. These loose papers were found at the business premise of Gupta Iron store. These are hand written kachi parchis showing various cash transactions relating to their money lending

Radha Madhav Eco-Industrial Park, Valsad vs. Asstt. Commissioner of Income Tax, Central Circle-1, Vapi

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

ITA 632/SRT/2024[2018-19]Status: DisposedITAT Surat05 Mar 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

profit element of on-money receipts without considering that the said plots were not sold to the parties mentioned in the loose papers. 3. On the facts and circumstances of the case as well as law on the subject, the learned CIT(Appeals) has erred in confirming addition of Rs.1 ... profit element of on-money receipts without considering that the said plots were not sold to the parties mentioned in the loose papers. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(Appeals) has erred in confirming addition of Rs.38

Assistant Commissioner of Income Tax, Central Circle, Vapi vs. Radha Madhav Eco Industrial Park, Vapi

ITA 626/SRT/2024[2019-20]Status: DisposedITAT Surat05 Mar 2025AY 2019-20

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) Vs. The Acit, Radha Madhav Eco-Industrial Park, Central Circle - 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp - Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp - Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

Section 139Section 250

profit element of on-money receipts without considering that the said plots were not sold to the parties mentioned in the loose papers. 3. On the facts and circumstances of the case as well as law on the subject, the learned CIT(Appeals) has erred in confirming addition of Rs.1 ... profit element of on-money receipts without considering that the said plots were not sold to the parties mentioned in the loose papers. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(Appeals) has erred in confirming addition of Rs.38