On-money addition from a dumb loose sheet fails without independent corroboration and cannot override a registered sale deed.

Addition for alleged on-money or unexplained investment in immovable property cannot rest solely on a seized loose sheet without independent corroboration. The Tribunal noted that the loose sheet was found in the seller's case, had already been treated as a dumb document, and no material showed payment over and above the registered sale consideration. Applying the principle that a registered document cannot be displaced by uncorroborated oral or hearsay material, it held that adverse inference could not be drawn from a standalone document without supporting evidence. The deletion of the addition was therefore upheld in favour of the assessee.

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Issues: Whether addition for alleged on-money / unexplained investment in purchase of immovable property could be sustained solely on the basis of a seized loose sheet without any independent corroborative evidence.

Analysis: The addition rested only on a seized loose sheet found in the case of the seller, while no independent material was brought on record to prove that the assessee paid consideration over and above the amount recorded in the registered sale deed. The same seized document had already been treated as a dumb document in the seller's case, and the Tribunal had upheld the deletion of that addition. The settled principle applied was that a registered document cannot be displaced by uncorroborated oral or hearsay material, and adverse inference for on-money cannot be drawn from a standalone dumb document without supporting evidence.

Conclusion: The addition was unsustainable and the deletion made by the appellate authority was upheld in favour of the assessee.

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