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TMI Blog2017 (2) TMI 1357X X X X Extracts X X X X X X X X Extracts X X X X ..... umption does not mean that every document will result in some addition. For that purpose one has to mention as to the nature of document, nature and year of transaction, quantum as to how it should be treated, whether it is an investment, expenditure, income or earning, and unless all these things are clear, no addition can be made - thus we are clear that every document will not result in some ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssession of Assessee during search and seizure operation on 10th November, 2006. For our purpose, it is sufficient to notice that after examining all the documents and applying presumption under Section 292C of Act, 1961, the Commissioner of Income Tax (Appeals) [hereinafter referred to as 'CIT(A)'], allowed deduction of ₹ 3.58 Lakhs, but in respect of documents which were not very c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... #8377; 56,44,332/- are directed to be deleted. 5. The Tribunal has upheld the aforesaid view taken by CIT(A) that the dumb documents which are not understandable and in respect whereof nothing can be done, no addition can be made on that basis. 6. Though appellant has formulated 11 substantial questions of law, but Sri Siddharth Dhaon, learned counsel appearing for appellant submitted that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e clear that every document will not result in some addition, as has been recorded by Tribunal. It is for this reason that Tribunal has stated those documents as 'dumb document', which obviously will result in automatic denial of addition. 7. It is not the case of appellant that particular document which was very clear and would have resulted in some addition, has been ignored by the CI ..... X X X X Extracts X X X X X X X X Extracts X X X X
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