Tribunal Rejects Income Attribution Due to Lack of Evidence in Notations Found During Search.

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....Loose papers found during a search at the residences of individuals contained notings and calculations presumed by the Assessing Officer (AO) to relate to undisclosed income and investments of one individual. However, the evidence failed to establish any connection between the notings and that individual's activities or sources of income. The notings pertained to expenses, vehicle purchases, and numerical entries, but no regular income was identified for that person to correlate with such expenses. The loose papers were found at another individual's residence, whose business records were accepted. The Tribunal held that the AO wrongly attributed the loose paper notings to the first individual without establishing any link or means of income.........