On-money addition cannot be extrapolated across flats or years without cogent evidence linking seized material to the addition.

An addition for alleged on-money receipts based on seized loose papers could not be sustained where the material related only to one flat and did not provide cogent evidence for a blanket addition across other flats or later assessment years. The HC noted that, in the assessee's own earlier year, extrapolation had already been rejected as impermissible where the addition rested on guesswork rather than reliable evidence. Applying that reasoning, the year's addition was treated as repetitive and presumptive, not evidence-based, and the deletion of the on-money addition was upheld.

---

---

Issues: Whether the addition made on account of alleged on-money receipt could be sustained on the basis of seized loose papers and extrapolation to other flats and assessment years.

Analysis: The seized material related to a particular flat and did not furnish cogent evidence for making a blanket addition across all flats or for later assessment years. The prior decision in the assessee's own case for the immediately preceding year had already held that, in the absence of reliable evidence, extrapolation was impermissible and the addition was based only on guesswork. The addition for the year under consideration was thus found to be repetitive and presumptive rather than evidence-based.

Conclusion: The deletion of the on-money addition was upheld and the Revenue's appeal failed.

Ratio Decidendi: An addition based on alleged undisclosed receipts cannot be extended by extrapolation to other transactions or years without cogent evidence linking the seized material to those additions.

---