Uncorroborated computer printout cannot prove undisclosed income in block assessment without reliable evidence of actual sale consideration.

An unsigned, undated computer printout recovered from an employee's computer, described in its own notes as a projection and containing internal anomalies, could not by itself establish undisclosed income from flat sales in block assessment. Chapter XIV-B requires undisclosed income to be detected from search material with a live nexus to the search, and a loose or "dumb" document needs independent, reliable corroboration before it can support an addition. In the absence of examination of the author or purchasers and without tangible evidence of understatement of consideration, the addition was held unsustainable in law.

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Issues: Whether the addition sustained on the basis of an unsigned, undated computer printout recovered from an employee's computer, without independent corroboration, could validly be treated as undisclosed income from sale of flats in the block assessment.

Analysis: Chapter XIV-B permits assessment only of undisclosed income detected as a result of search and the addition must rest on material having a live nexus with the search. The seized printout in question was described in its own notes as a projection, contained anomalies in floor-wise rates and area figures, and was not supported by examination of the alleged author or the purchasers. In the absence of corroborative material, a loose or "dumb" document cannot by itself establish the actual sale price or justify adoption of a uniform enhanced rate for all floors. The assessee's explanation was plausible and the Revenue failed to produce reliable tangible evidence to prove understatement of consideration.

Conclusion: The addition sustained by the appellate authority was rightly held unsustainable in law, and the question was answered in favour of the assessee and against the Revenue.

Ratio Decidendi: In a block assessment, an uncorroborated loose or computer-generated projection document cannot, by itself, be treated as proof of undisclosed income unless supported by independent, reliable evidence establishing the actual transaction value.

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