Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or ownership.

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....Third-party loose sheets may trigger investigation but cannot, without reliable evidence linking the assessee to the recorded transaction, prove unexplained expenditure. Presumptions attached to seized documents apply to the person from whose possession or control they are recovered; they do not establish the alleged payer, source or movement of funds. Actual incurrence is foundational, so an uncorroborated allegation cannot shift the burden of proof. Nor does a third-party reference establish ownership of unrecorded money; the statutory requirements for unexplained money and expenditure are distinct. These deficiencies made both additions unsustainable. Evaluation of material already on the assessment record does not amount to admitting additional evidence.....