Onus to prove Third party documents found during search is on department

Brief fact Assessee was a Non-resident individual. During the course of search operation u/s 132 of the Act carried out at the site office of J.P. Construction, certain loose papers were seized which showed that Jigna Shah, the assessee, had advanced Rs.50 lac to Jigen Shah before Feb 1996 and it was also mentioned that interest @ 12% has been charged by Jigna Shah on such loan. Property of Rs.40 lac was also shown to be given to assessee to which the AO accepted as part payment of interest. Notice u/s 153C was issued and in response, the assessee filed NIL return of Income. It was submitted b...