Evidentiary corroboration required: seized ledger entries alone cannot support an 'on money' addition in reassessment proceedings.

Seized loose-sheet entries alone cannot be converted into taxable income in reassessment proceedings without independent corroboration; the piece of evidence must demonstrate payment or be supported by contemporaneous proof to attribute 'on money' to the assessee. Applying this evidentiary principle in a Section 147 reassessment context, the Tribunal found the seized entries referencing the assessee insufficient to sustain an addition, and therefore the impugned addition was deleted with the appeal allowed in favour of the assessee.

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Issues: Whether the addition of Rs. 12,50,000 made under the assessment framed under Section 147 of the Income tax Act, 1961 as alleged 'on money' based on seized loose sheets is sustainable in the absence of independent corroboration.

Analysis: The Tribunal examined the assessment order dated 06.03.2024 and the seized loose sheets reproduced therein which reference the assessee's name and the impugned amount. The assessing authority relied on the seized material to make an addition of Rs. 12,50,000 as on money. However, the seized entries themselves do not demonstrate that any on money was actually paid; there is no independent or contemporaneous corroborative evidence establishing payment. In the context of reassessment proceedings under Section 147 of the Income tax Act, 1961, reliance on seized documents requires evidentiary corroboration to convert entries into taxable income. Absent such corroboration, the Tribunal found the addition to be unsubstantiated.

Conclusion: The addition of Rs. 12,50,000 treated as on money is deleted and the assessee's appeal is allowed; decision is in favour of the assessee.

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