Addition towards unexplained investment u/s 69 based on presumptions unsustainable

Anoop Kumar Soni Vs DCIT (ITAT Delhi) ITAT Delhi held that entire addition towards unexplained investment under section 69 of the Income Tax Act merely on the basis of presumption is unsustainable in law. Facts- During the course of search on M/s Jindal Bullion Ltd. Group (JBL) on 05.01.2017, data pertaining to the F.Y. 2014­-15, 2015-16, and 2016-17 in the form of digital data and loose sheets were seized. Digital data was maintained in a software named “Hazir Johri” at the residential cum business premises of Sh. Kusharg Jindal (promoter and Director of JBL) in a dongle. Loose sheets de...