← All Phrases

“dumb documents”

Search & SeizureSection 132Section 132946 judgments

The decision most relied on for dumb documents is CBI v. V.C. Shukla (3 SCC 410), cited in 442 judgments on BharatTax.

Leading authorities on dumb documents

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.

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.

CIT v. Lavanya Land (P) Ltd.
83 Taxmann.com 161 · 2017 · High Court
172
citing judgments

In a search assessment under Section 153A or 153C, additions cannot be sustained if the material or transactions relied upon do not relate or pertain to the assessee. Regular books of accounts not unearthed during search do not constitute incriminating material to justify additions.

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.

CIT v. Sant Lal
118 Taxmann.com 432 · 2020 · High Court
154
citing judgments

An addition to income cannot be made solely on the basis of entries in a diary seized from a third party if the diary is not found in the assessee's premises, not in the assessee's handwriting, and the revenue fails to provide corroborative evidence linking the assessee to the diary.

Ashwani Kumar v. ITO
39 ITD 183 · 1991 · High Court
122
citing judgments

For figures in a 'dumb document' to be treated as the assessee's income, the revenue must provide necessary evidence to prove that these figures represent income earned by the assessee and that the alleged documents have materialized into transactions.

Revenue in CIT v. Sunil Kumar Sharma
165 Taxmann.com 846 · 2024 · Supreme Court
118
citing judgments

Independent corroborative evidence is required for making additions to income based on entries in regular books of accounts or seized material. Unverified 'dumb documents' found during a search cannot be the sole basis for determining undisclosed income without such corroboration.

Judgments citing dumb documents

DCIT, CC-I, Chandigarh vs. M/S Manohar Infrastructure & Construction Pvt. Ltd., Chandigarh

Appeal stands partly allowed

ITA 1306/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh07 Oct 2025AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1285/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2011-12) & 2. आयकर अपील सं. / Ita No.1286/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Manohar Infrastructure & Dcit Constructions Pvt. Ltd. Central Circle-1 बनाम/ Vs. Sco No 139-141 Sector 17-C Chandigarh. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकर अपील सं. / Ita No.1306/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S Manohar Infrastructure & बनाम/ Central Circle-1 Constructions Pvt. Ltd. Chandigarh. Sco No 139-141 Sector 17-C Vs. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Harry Rikhy (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sarabjeet Singh (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 01/10/2025

For Appellant: Shri Harry Rikhy (Advocate) – Ld. ARFor Respondent: Shri Sarabjeet Singh (CIT) – Ld. DR
Section 131Section 132(1)Section 132(4)Section 153ASection 153A(1)(b)

assessee submitted the affidavits of the sellers to support his submissions and pleaded that the said document was merely a dumb document which could not be relied upon to make any addition in the hands of the assessee. The Ld. AO still rejected the aforesaid submissions also. The cash component ... persons whose statements were recorded by AO were not offered to be cross-examined. The impugned additions were made on the basis of dumb documents which merely contained estimate of calculation made by the broker Shri Sekhon. The assessee already made disclosure of Rs.240.51 Lacs

Manohar Infrastructure and Constructions Pvt. Ltd., Chandigarh vs. DCIT, CC-1, Chandigarh

Appeal stands partly allowed

ITA 1286/CHANDI/2017[2012-13]Status: DisposedITAT Chandigarh07 Oct 2025AY 2012-13

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1285/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2011-12) & 2. आयकर अपील सं. / Ita No.1286/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Manohar Infrastructure & Dcit Constructions Pvt. Ltd. Central Circle-1 बनाम/ Vs. Sco No 139-141 Sector 17-C Chandigarh. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकर अपील सं. / Ita No.1306/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S Manohar Infrastructure & बनाम/ Central Circle-1 Constructions Pvt. Ltd. Chandigarh. Sco No 139-141 Sector 17-C Vs. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Harry Rikhy (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sarabjeet Singh (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 01/10/2025

For Appellant: Shri Harry Rikhy (Advocate) – Ld. ARFor Respondent: Shri Sarabjeet Singh (CIT) – Ld. DR
Section 131Section 132(1)Section 132(4)Section 153ASection 153A(1)(b)

assessee submitted the affidavits of the sellers to support his submissions and pleaded that the said document was merely a dumb document which could not be relied upon to make any addition in the hands of the assessee. The Ld. AO still rejected the aforesaid submissions also. The cash component ... persons whose statements were recorded by AO were not offered to be cross-examined. The impugned additions were made on the basis of dumb documents which merely contained estimate of calculation made by the broker Shri Sekhon. The assessee already made disclosure of Rs.240.51 Lacs

Manohar Infrastructure and Constructions Pvt. Ltd., Chandigarh vs. DCIT, CC-1, Chandigarh

Appeal stands partly allowed

ITA 1285/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh07 Oct 2025AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.1285/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2011-12) & 2. आयकर अपील सं. / Ita No.1286/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) M/S Manohar Infrastructure & Dcit Constructions Pvt. Ltd. Central Circle-1 बनाम/ Vs. Sco No 139-141 Sector 17-C Chandigarh. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) & 3. आयकर अपील सं. / Ita No.1306/Chandi/2017 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S Manohar Infrastructure & बनाम/ Central Circle-1 Constructions Pvt. Ltd. Chandigarh. Sco No 139-141 Sector 17-C Vs. Chandigarh "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecm-8616-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Harry Rikhy (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Shri Sarabjeet Singh (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 09-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 01/10/2025

For Appellant: Shri Harry Rikhy (Advocate) – Ld. ARFor Respondent: Shri Sarabjeet Singh (CIT) – Ld. DR
Section 131Section 132(1)Section 132(4)Section 153ASection 153A(1)(b)

assessee submitted the affidavits of the sellers to support his submissions and pleaded that the said document was merely a dumb document which could not be relied upon to make any addition in the hands of the assessee. The Ld. AO still rejected the aforesaid submissions also. The cash component ... persons whose statements were recorded by AO were not offered to be cross-examined. The impugned additions were made on the basis of dumb documents which merely contained estimate of calculation made by the broker Shri Sekhon. The assessee already made disclosure of Rs.240.51 Lacs

Deputy Commissioner of Income Tax (It), Visakhapatnam vs. Shri Apparao Mukkamala, Usa

In the result, the appeal filed by the revenue is dismissed, while for the cross-objection filed by the assessee is allowed

ITA 354/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam30 Sept 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON’BLE (Judicial Member), SHRI BALAKRISHNAN. S, HON’BLE (Accountant Member)

Section 144C(3)Section 147Section 148Section 153CSection 69A

assessee assailed the impugned addition of Rs. 3.75 crore (supra) based on multi-facet grounds, viz. (i). that the seized scribbling was a dumb document of no evidentiary value; (ii). that no corroborative evidence to substantiate the impugned addition was brought on record; (iii). that opportunity to cross-examine ... which would irrefutably evidence that the assessee had received any on money on the sale of the shares. It is settled law that dumb documents found from third parties cannot, by themselves, constitute evidence of undisclosed income of another person. We find that neither corroborative evidence has been brought

Rajesh Balvantrai Brahmbhatt, Ahmedabad vs. The Pr. CIT(Central), Ahmedabad

In the result, the appeals of the assessee is allowed

ITA 1158/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad30 Sept 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

Section 131Section 132Section 133(6)Section 133ASection 143(3)Section 153CSection 263

that the seized documents, which record the transaction value and contain a detailed schedule of cheque and cash payments, could not be dismissed as “dumb documents.” Once the cheque payments reflected therein are accepted as genuine, the accompanying cash payments necessarily stand corroborated. 4. The learned DR further pointed

Rajesh Balvantrai Brahmbhatt, Ahmedabad vs. The Pr. CIT(Central), Ahmedabad

In the result, the appeals of the assessee is allowed

ITA 1157/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad30 Sept 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

Section 131Section 132Section 133(6)Section 133ASection 143(3)Section 153CSection 263

that the seized documents, which record the transaction value and contain a detailed schedule of cheque and cash payments, could not be dismissed as “dumb documents.” Once the cheque payments reflected therein are accepted as genuine, the accompanying cash payments necessarily stand corroborated. 4. The learned DR further pointed

Deputy Commissioner of Income Tax, Central Circle-2, Noida vs. Saraswati Ammal Education and Charitable Trust, Chennai

Appeals are dismissed

ITA 2291/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 133ASection 142Section 144Section 153Section 153CSection 69ASection 69C

have added the same in the hands of the Assessee trust. 13. The Ld. AR argued that addition has been made based on the dumb documents, wherein it is mentioned the word ‘capitation fees’ which do not bear name of the Assessee trust or date of receipt or mode ... transaction. Apart from the same, those dumb documents were seized from the custody of Sh. V. Mathiyalgan written in his Saraswati Ammal Educational & Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating

Deputy Commissioner of Income Tax, Central Circle-2, Noida vs. Saraswati Ammal Education and Charitable Trust, Chennai

ITA 2290/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Sept 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 133ASection 142Section 144Section 153Section 153CSection 69ASection 69C

have added the same in the hands of the Assessee trust. 13. The Ld. AR argued that addition has been made based on the dumb documents, wherein it is mentioned the word 'capitation fees' which do not bear name of the Assessee trust or date of receipt or mode ... transaction. Apart from the same, those dumb documents were seized from the custody of Sh. V. Mathiyalgan written in his hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating to the allegation that such receipts belonged

Dy. Commissioner of Income Tax, Noida vs. Saraswati Ammal Education and Charitable Trust, Chennai

Appeals are dismissed

ITA 2289/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Sept 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 133ASection 142Section 144Section 153Section 153CSection 69ASection 69C

have added the same in the hands of the Assessee trust. 13. The Ld. AR argued that addition has been made based on the dumb documents, wherein it is mentioned the word ‘capitation fees’ which do not bear name of the Assessee trust or date of receipt or mode ... transaction. Apart from the same, those dumb documents were seized from the custody of Sh. V. Mathiyalgan written in his Saraswati Ammal Educational & Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating

Dy. Commissioner of Income Tax, Noida vs. Saraswati Ammal Education and Charitable Trust, Chennai

Appeals are dismissed

ITA 2288/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Sept 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 133ASection 142Section 144Section 153Section 153CSection 69ASection 69C

have added the same in the hands of the Assessee trust. 13. The Ld. AR argued that addition has been made based on the dumb documents, wherein it is mentioned the word ‘capitation fees’ which do not bear name of the Assessee trust or date of receipt or mode ... transaction. Apart from the same, those dumb documents were seized from the custody of Sh. V. Mathiyalgan written in his Saraswati Ammal Educational & Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating

Saraswathi Ammal Educational and Charitable Trust, Chennai vs. ACIT Centre Circle II, Noida

Appeals are dismissed

ITA 2182/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Sept 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 133ASection 142Section 144Section 153Section 153CSection 69ASection 69C

have added the same in the hands of the Assessee trust. 13. The Ld. AR argued that addition has been made based on the dumb documents, wherein it is mentioned the word ‘capitation fees’ which do not bear name of the Assessee trust or date of receipt or mode ... transaction. Apart from the same, those dumb documents were seized from the custody of Sh. V. Mathiyalgan written in his 12 ITA No. 2181/Del/2023 & ors Saraswati Ammal Educational & Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey

Saraswathi Ammal Educational and Charitable Trust, Chennai vs. ACIT Centre Circle II, Noida

Appeals are dismissed

ITA 2181/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Sept 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 133ASection 142Section 144Section 153Section 153CSection 69ASection 69C

have added the same in the hands of the Assessee trust. 13. The Ld. AR argued that addition has been made based on the dumb documents, wherein it is mentioned the word ‘capitation fees’ which do not bear name of the Assessee trust or date of receipt or mode ... transaction. Apart from the same, those dumb documents were seized from the custody of Sh. V. Mathiyalgan written in his Saraswati Ammal Educational & Charitable Trust Vs. ACIT hand writing and no incriminating material whatsoever were found at the premises of the Assessee in the survey conducted by the Department corroborating

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

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

ITA 890/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

section 69A for AY 2018–19 about ₹5.05 crores in aggregate. Equally significant, the Tribunal described the loose sheets as rough jotting aptly as “dumb documents” and recorded that the limited sustainment flowed essentially from the assessee’s search-time offer to buy peace Department. 43. The penalty appeals must ... proved linkage to any unrecorded income entry; there is, instead, a set of rough notings and chats described by the Tribunal itself as dumb documents accompanied by a surrender made to buy peace. Such material may, in a given factual matrix, sustain a calibrated quantum addition; but it does

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are

ITA 889/MUM/2025[2013-14]Status: DisposedITAT Mumbai29 Sept 2025AY 2013-14
Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

about ₹5.05 crores in aggregate. Equally significant, the Tribunal described the loose sheets recorded as rough jotting aptly as "dumb documents” and recorded that the limited sustainment flowed essentially from the assessee's search-time offer to buy peace rather than from any corroborative evidence unearthed by the Department ... proved linkage to any unrecorded income entry; there is, instead, a set of rough notings and chats described by the Tribunal itself as dumb documents accompanied by a surrender made to buy peace. Such material may, in a given factual matrix, sustain a calibrated quantum addition; but it does

DCIT, Central Circle-3(2), Mumbai vs. M/S Viraj Profiles Private Limited, Mumbai

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

ITA 888/MUM/2025[2011-12]Status: DisposedITAT Mumbai29 Sept 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

section 69A for AY 2018–19 about ₹5.05 crores in aggregate. Equally significant, the Tribunal described the loose sheets as rough jotting aptly as “dumb documents” and recorded that the limited sustainment flowed essentially from the assessee’s search-time offer to buy peace Department. 43. The penalty appeals must ... proved linkage to any unrecorded income entry; there is, instead, a set of rough notings and chats described by the Tribunal itself as dumb documents accompanied by a surrender made to buy peace. Such material may, in a given factual matrix, sustain a calibrated quantum addition; but it does

DCIT, Central Circle-3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

In the result, all the appeals filed by the Revenue are

ITA 872/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Sept 2025AY 2017-18

Bench: Hon'Ble Income Tax Appellate Tribunal, Mumbai 'F' Bench M/S Viraj Profiles Private Limited Summary Of Penalty Appeals Sr. No. Nature Of Addition/ Disallowance Ay 2011-12 U/S 271(1)(C) Ay 2013-14 U/S 271(1)(C) Ay 2015-16 U/S 271(1)(C) Ay 2017-18 U/S 271Aab Ay 2018-19 U/S 271Aab (Amt In Inr) Total Addition Made U/S 143(3)

Section 143(3)Section 153ASection 271(1)(c)Section 271ASection 37Section 69ASection 69C

about ₹5.05 crores in aggregate. Equally significant, the Tribunal described the loose sheets recorded as rough jotting aptly as “dumb documents” and recorded that the limited sustainment flowed essentially from the assessee's search-time offer to buy peace rather than from any corroborative evidence unearthed by the Department ... proved linkage to any unrecorded income entry; there is, instead, a set of rough notings and chats described by the Tribunal itself as dumb documents accompanied by a surrender made to buy peace. Such material may, in a given factual matrix, sustain a calibrated quantum addition; but it does

DCIT, Central Circle-3(2), Mumbai vs. Viraj Profiles Private Limited, Mumbai

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

ITA 871/MUM/2025[2015-16]Status: DisposedITAT Mumbai29 Sept 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 153ASection 271(1)(c)Section 69A

section 69A for AY 2018–19 about ₹5.05 crores in aggregate. Equally significant, the Tribunal described the loose sheets as rough jotting aptly as “dumb documents” and recorded that the limited sustainment flowed essentially from the assessee’s search-time offer to buy peace Department. 43. The penalty appeals must ... proved linkage to any unrecorded income entry; there is, instead, a set of rough notings and chats described by the Tribunal itself as dumb documents accompanied by a surrender made to buy peace. Such material may, in a given factual matrix, sustain a calibrated quantum addition; but it does

ACIT, Central Circle-2(4), Bangalore vs. Ramchandra Naveen, Bangalore

ITA 2083/BANG/2024[2018-19]Status: DisposedITAT Bangalore26 Sept 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 153A

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER

ACIT, Central Circle-2(4), Bangalore vs. Ramchandra Naveen, Bangalore

ITA 2082/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 132(4)Section 153A

INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL MEMBER

Super Cassettes Industries Private Limited, Delhi vs. DCIT Central Circle 3, Delhi

ITA 7/DEL/2024[2017-18]Status: DisposedITAT Delhi25 Sept 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

action. It is a predominant judicial view that no arbitrary addition to the income can be made by the Assessing Officer based on the dumb documents, loose papers containing scribbling, rough/vague notings, in the absence of any corroborative material, evidence on record and finding that such dumb documents had materialized ... lines, the Hon'ble Delhi ITAT in case of Ashwani Kumar Vs. I TO [1991] 39 ITD 183 held that in the case of dumb document, revenue should have necessary evidence to prove that the figures represent incomes earned by the assessee. Similar is the decision in the case