Addition Based on Third-Party Excel Sheet Without Evidence of Payment Deleted by ITAT

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. Backgroun...