On-Money Addition Based on Excel Sheet Deleted: No Corroborative Evidence

Najmussaher Saeed Khan Vs ACIT (ITAT Mumbai) The AO made additions of ₹30 lakh each (later restricted to ₹15 lakh each by CIT(A)) under Section 69 alleging on-money payment in cash for purchase of a flat, based solely on an excel sheet found in a third-party search and a general statement of the builder. The ITAT held that: There was no direct evidence linking the assessees to any cash payment The builder’s statement was general and not specific to the assessees No independent enquiry or cash trail was established by the AO The Tribunal emphasized that additions cannot be made merely o...