DCIT Vs Sudipta Ajoykumar Mukherjee (ITAT Mumbai)
The Income Tax Appellate Tribunal (ITAT), Mumbai Bench, in its order dated September 12, 2025, for Assessment Year 2018-19, dismissed an appeal filed by the Revenue (Deputy Commissioner of Income Tax) challenging the deletion of an addition of ₹80,00,000/- made under Section 69 of the Income-tax Act, 1961. The core dispute revolved around whether an uncorroborated entry in an Excel sheet seized during a third-party search was sufficient to prove that the assessee, Sudipta Ajoykumar Mukherjee, had made an unexplained cash investment.
Background of the Case
The proceedings against the assessee originated from a search and seizure operation conducted under Section 132 of the Act on May 7, 2018, against the Mohini Group, a real estate developer. During the search, an electronic document—an Excel sheet titled ‘Ashirwad Co-operative Housing Society Ltd.’—was found and seized from a third party (a building contractor related to the society). This sheet allegedly contained an entry indicating that the assessee had made a cash payment of ₹80,00,000/- towards the allotment of a flat in the society.
Based on this entry, the Assessing Officer (AO) issued a show-cause notice and subsequently treated the ₹80 lakh as unexplained investment, making an addition to the assessee’s total income under Section 69 of the Act. The AO completed the assessment at an income of ₹98,32,350/-.
