Additions Based on Loose Sheets Deleted – “Dumb Documents” Insufficient for 153A: ITAT Delhi

Dheeraj Chaudhary Vs ACIT (ITAT Delhi) Additions based on loose sheets deleted – “Dumb documents” without date/name cannot justify 153A additions – ITAT Delhi In Shri Dheeraj Chaudhary vs ACIT (A.Y. 2015-16), additions exceeding ₹2.10 crore were made u/s 153A based mainly on loose sheets seized during search proceedings. The assessee argued that the documents were merely rough estimates relating to property dealings, contained no dates or signatures, and could not be linked to the relevant assessment year. The ITAT observed that most seized papers lacked date, handwriting identificat...