Addition cannot be made merely based on document which is silent as to payer and payee

1. Allowed, subject to all just exceptions. 2. This is an appeal by the Revenue against the order dated 29th July, 2016 passed the Income Tax Appellate Tribunal (‘ITAT’) in ITA No. 3032/Del/2012 for the Assessment Year (‘AY’) 2004-05. 3. The Revenue is aggrieved by the order of ITAT whereby it deleted the addition of Rs. 80,50,000 to the income of the Respondent/Assessee by the Assessing Officer (‘AO’), which order was affirmed by the Commissioner of Income Tax (Appeals) [‘CIT (A)’]. 4. A search took place in the premises of the Respondent/Assessee pursuant to which certai...