Third-party loose sheet without corroboration cannot sustain reassessment addition for alleged cash payment.

A third-party loose excel sheet, without a clear nexus to the assessee's alleged purchase and without corroborative evidence, cannot by itself justify an addition in reassessment. The sheet related to a different project, while the record showed cheque payments and a notarised affidavit from the developer denying receipt of cash. In the absence of reliable linkage between the document and the assessee, the inference of undisclosed cash payment failed, and the addition was deleted.

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Issues: Whether the addition sustained in reassessment could rest solely on an excel sheet found during survey at a third party premises without proper nexus or corroboration with the assessee's alleged purchase transaction.

Analysis: The reassessment was founded on a loose excel sheet found in the course of survey on a builder's premises. The sheet related to a different project and did not satisfactorily correlate with the shop purchased by the assessee in 2021. The record also showed cheque payments and a notarized affidavit from the developer denying receipt of cash from the assessee. In the absence of corroborative material, the document by itself was not sufficient to sustain the inference that the assessee had made undisclosed cash payments.

Conclusion: The addition could not be sustained and was deleted in favour of the assessee.

Final Conclusion: The reassessment addition was set aside because the material relied upon did not establish a credible link between the assessee and the alleged cash payment.

Ratio Decidendi: A third-party loose sheet or excel extract, without corroboration and without a clear nexus to the assessee, cannot by itself justify an addition in assessment.

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