Unexplained investment requires corroborative proof; an unauthenticated third-party loose sheet cannot alone establish undisclosed property consideration.

An unauthenticated loose sheet seized from a third party cannot, without cogent independent corroboration, establish understatement of property consideration or unexplained investment. The registered sale deed, banking records and tax deduction records supported the disclosed consideration, while the loose sheet lacked signatures, identified authorship and date, was outside regular books, and conflicted materially with documented transaction details. As no enquiry from sellers, evidence of on-money receipt, or cash trail was produced, suspicion could not replace proof. The article notes that the unexplained-investment addition was deleted.

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Issues: Whether an addition for unexplained investment could be sustained solely on an unauthenticated loose sheet seized from a third party, without corroborative evidence of payment of additional consideration.

Analysis: The disclosed consideration was supported by the registered sale deed, banking records and tax deduction records. The loose sheet was neither found from the assessee nor from either seller; it bore no signature or authentication, its author and date were unestablished, and it was not part of regular books of account. Its particulars, including cheque numbers and consideration figures, materially conflicted with the documented transaction. The Revenue made no independent enquiry from the sellers, obtained no evidence of receipt of on-money, and identified no cash trail. A loose or dumb document, uncorroborated by cogent independent material, could not establish understatement of consideration; suspicion could not substitute proof.

Conclusion: The addition of Rs. 1,20,06,000 as unexplained investment was unsustainable and was deleted in favour of the assessee.

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