Unexplained investment addition cannot rest on a lone Excel entry without corroborative evidence or assessee-linked proof.

An addition as unexplained investment under section 69 was found unsustainable where it was based only on a third-party Excel-sheet entry showing Rs. 8,000, later multiplied to Rs. 8,00,000 without any supporting material. No independent document, corroborative evidence, or assessee-linked record was produced to establish the alleged cash payment. In the absence of concrete evidence, the addition rested on presumption and suspicion rather than proof, and was therefore deleted in favour of the assessee.

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Issues: Whether the addition of Rs. 8,00,000 as unexplained investment under section 69, based only on an Excel sheet entry of Rs. 8,000 multiplied by 100 without supporting material, was sustainable.

Analysis: The addition rested on a solitary Excel-sheet entry found in the search of a third party, and the figure written therein was only Rs. 8,000. No independent document, corroborative evidence, or material from the assessee was brought on record to justify treating that figure as Rs. 8,00,000. The conclusion reached by the lower authorities was therefore founded only on presumption and suspicion, not on concrete evidence linking the assessee to the alleged cash payment.

Conclusion: The addition was not sustainable and was deleted. The issue was decided in favour of the assessee.

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