Loose Papers Found with Third Party Cannot Justify Addition Without Corroborative Evidence: ITAT Nagpur

ACIT Vs Sanjay Gaurishankar Agrawal (ITAT Nagpur) During a search conducted at the premises of Shri Suresh Bajoria  certain loose   were found. These papers contained handwritten financial entries & the name “Chhotubhai”. In his statement recorded u/s 132(4), Shri Bajoria initially stated that the papers related to him & his friend “Chhotubhai”, whom the AO assumed to be the assessee, Sanjay Agrawal. The total credit on these pages was ₹5,33,550. AO, without adequate explanation, extrapolated the figure by two decimal places & treated it as ₹5,33,55,000, concluding...