Unexplained investment addition cannot rest on an unsigned loose sheet without corroborative evidence.

An addition for unexplained investment under section 69B cannot be sustained solely on an unsigned loose sheet recovered from a third party's premises when the paper is neither signed by the assessee nor shown to be in the handwriting of the assessee or the searched person. Where the searched person denies any cash payment and the assessee states that property-related payments were made through banking channels, independent corroborative material is required before the document can support an addition. In the absence of such corroboration, the loose paper has no evidentiary value sufficient to justify the addition, which was deleted.

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Issues: Whether an addition for unexplained investment under section 69B of the Income-tax Act, 1961 could be sustained solely on the basis of an unsigned loose sheet recovered from the premises of a third party, without corroborative material.

Analysis: The addition was founded on a loose unsigned paper seized from the premises of a searched person. The document did not bear the assessee's signature and was not in the handwriting of either the assessee or the searched person. The searched person denied receiving any cash payment, while the assessee maintained that the property-related payments were made through banking channels. In the absence of independent corroborative evidence, an unsigned and unverified loose paper could not, by itself, form the basis of an addition under section 69B.

Conclusion: The addition of Rs. 30,00,000/- was not sustainable and was deleted, with the result that the issue was decided in favour of the assessee.

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