Section 69A Addition Invalid When Based Only on undated Third-Party Loose Papers

Air Con Systems (India) Pvt. Ltd Vs DCIT (ITAT Delhi) ITAT Delhi deletes ₹62 lakh addition u/s 69A – Undated loose paper found in third-party search, no cash found, no corroboration & even wrong assessment year A search was conducted in the case of Sanjay Jain & Mehtas Group on 26.10.2020 & again on 11.02.2021. During this action, a loose sheet (page 46 of Annexure A-7 from FCB-1) was found not from the assessee, but from the residence of a third party, Shri Surender Gupta. The AO presumed that handwritten notings such as “CASH ANTH HR” & “CASH ANTH YOG” represented...