Handwriting expert evidence must be weighed cautiously; uncorroborated opinion will not justify reopening seized documents.

Handwriting expert opinion is relevant but weak evidence and must be weighed cautiously, especially when it is unsupported by corroboration. Where the assessee's experts gave detailed reasons and were not cross-examined, while the Revenue's expert offered only a bare conclusion and accepted dissimilarities and possible variation in cross-examination, the Tribunal declined to reopen the seized loose sheets for fresh evidentiary inquiry. It also considered the long lapse of time and refused to remit the matter for further cross-examination. The Revenue's Rule 29 application was rejected, and the earlier dismissal of the departmental appeal remained undisturbed.

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Issues: Whether the Revenue's application under Rule 29 of the Appellate Tribunal Rules, 1963 for admission of handwriting expert evidence and for a fresh adjudication on the seized documents should be allowed.

Analysis: The dispute turned on competing handwriting expert opinions regarding the seized loose sheets. The Tribunal noted that expert evidence is admissible but is inherently weak and must be weighed with caution, particularly where it is unsupported by corroborative material. It further observed that the assessee's experts had given detailed reasons and had not been cross-examined, whereas the Revenue's expert gave a bare conclusion and, in cross-examination, accepted dissimilarities and the possibility of variation. The Tribunal also relied on the long passage of time and declined to reopen the matter or send it back for further cross-examination.

Conclusion: The Revenue's Rule 29 application was rejected and the earlier dismissal of the departmental appeal was left undisturbed.

Final Conclusion: The seized documents were not reopened for fresh evidentiary inquiry, and the departmental challenge to the deletion of additions failed.

Ratio Decidendi: Handwriting expert opinion, though relevant, cannot by itself displace a reasoned contrary view where it lacks supporting corroboration and the opposing expert evidence is detailed and unshaken.

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