On-Money Addition Deleted – Loose Papers Builder Statements Alone Insufficient to Prove Unexplained Investment U/s 69

Nirmala Pennechand Sarda Vs ITO (ITAT Mumbai)

ITAT Mumbai deleted addition of ₹54.10 lakh made u/s 69 towards alleged on-money payment for purchase of a commercial unit, holding that the addition was based only on rough loose papers seized from a third party during search on Surana Group. Tribunal observed that the jotting “613/14-manishji – 108.216” neither mentioned assessee’s name nor established any nexus with her transaction, and no corroborative evidence or independent enquiry was conducted by AO.

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