On-Money Addition Deleted – Loose Papers Builder Statements Alone Insufficient to Prove Unexplained Investment U/s 69

Nirmala Pennechand Sarda Vs ITO (ITAT Mumbai) ITAT Mumbai deleted addition of ₹54.10 lakh made u/s 69 towards alleged on-money payment for purchase of a commercial unit, holding that the addition was based only on rough loose papers seized from a third party during search on Surana Group. Tribunal observed that the jotting “613/14-manishji – 108.216” neither mentioned assessee’s name nor established any nexus with her transaction, and no corroborative evidence or independent enquiry was conducted by AO. The Bench noted that summary sheets prepared by AO showed no on-money receipts fo...