Loose Sheets Found in Employee’s Two-Wheeler Not Valid Basis for Unaccounted Sales Addition

DCIT Vs Zen Industries Pvt. Ltd. (ITAT Ahmedabad) In this case, the entire addition was triggered by certain loose sheets (pages 156–159 of Annexure A/3) found not from the assessee’s premises but from a two-wheeler belonging to an employee. These documents contained handwritten figures in coded form without any identifying particulars such as name of the assessee, name of parties, description of goods, quantity, rate, delivery details, or payment trail. Despite this, the Assessing Officer treated the figures as representing unaccounted sales of the assessee to entities of the MHS Group, ...