Third-party seized document could not prove accrued interest without corroboration, so the addition was deleted.

An addition for alleged accrued interest based on a seized third-party paper was unsustainable because the document was not in the assessee's handwriting, was unsigned by her, and was found at another person's premises. Read with the seizing person's statement and letter, the paper showed only an estimate of loss for settlement purposes, not proof that interest was actually received or had accrued. As the Revenue produced no corroborative material to show property transfer or any other act establishing accrual, the Department failed to discharge the burden of proving a contrary inference. The deletion of the addition was therefore upheld.

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Issues: Whether the addition made on account of alleged accrued interest on the basis of a seized third-party document was sustainable.

Analysis: The seized paper was found at a third party's premises and was neither in the assessee's handwriting nor signed by her. The document itself, as read with the statement and letter of the person from whom it was seized, indicated that the interest figure was worked out to estimate loss and to facilitate settlement, not to evidence interest actually received or accrued. The Revenue did not bring any material to dislodge the finding that no property transfer or other corroborative act had been proved, and therefore the inference of actual accrual was not established. The burden to prove a contrary inference from the document lay on the Department.

Conclusion: The addition on account of accrued interest was rightly deleted and the Revenue's challenge failed.

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