Third-party document evidence is insufficient for unexplained investment addition without corroboration linking the assessee to the transaction.

An addition for unexplained investment cannot be sustained on the basis of an unsigned excel sheet recovered from a third party's premises unless corroborative material links the assessee to the alleged transaction. Here, the assessee denied any property purchase or financial dealing with the developer, and the Revenue failed to identify a booked unit, cheque payment, or other supporting evidence establishing nexus with the entries. The fact that the relevant unit was purchased by another entity further weakened the Revenue's case. On these facts, the document alone was insufficient to justify addition under section 69 of the Income-tax Act, 1961, and the addition was deleted.

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Issues: Whether the addition of Rs. 9.95 crores as unexplained investment on the basis of an excel sheet found from a third party's premises, without corroborative evidence linking the assessee to the alleged transaction, was sustainable.

Analysis: The excel sheet was found from the premises of a third party and was unsigned. The assessee denied any purchase of property or financial dealing with the developer, and the revenue did not establish the nature of the alleged transaction or identify any booked unit, cheque payment, or supporting material connecting the assessee to the entries in the sheet. The record also showed that the relevant unit had been purchased by another entity, which undermined the revenue's assertion. In these circumstances, the document by itself was insufficient to sustain an addition without corroboration and without material establishing the assessee's involvement.

Conclusion: The addition under section 69 of the Income-tax Act, 1961 was rightly deleted, and the Revenue's challenge failed.

Ratio Decidendi: An addition for unexplained investment cannot rest solely on entries in a third-party document unless the revenue establishes, by corroborative evidence, a direct nexus between the assessee and the alleged transaction.

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