Addition merely based on inference drawn from documents seized from third party is not valid

Facts of the Case : The present case is related to search & seizure action carried out in case of Sh. S.K. Gupta (‘third party’) in respect of companies and other business entities which were controlled by him or owned by him or different individuals connected with him. The assessee was one such individual. During the assessment proceedings u/s 143(3) read with section 153A, AO not being satisfied with the explanations made by the assessee and based on extract of some hand written ledgers indicating name “Shri Anil Khandelwal’ seized from Sh. S.K. Gupta, made addition to the income...