Tax Officials Cannot Make Addition Based on Loose Papers Without Specific Evidence of Unaccounted Money in Property Sales

ITAT overturned addition of unaccounted money allegedly received by assessee representing 20% of total consideration. Addition was based on extrapolation from loose papers discovered during search operations. Tribunal held that extrapolation for on-money receipts from shop sales cannot be sustained where no specific evidence was found during search, no proper investigation was conducted, and key witness was not questioned about incriminating documents. Additionally, many flats were sold to parties different from those listed in loose sheets, and buyers were unrelated parties. Given CIT(A) had already deleted similar additions for another partner in joint venture project Ganga Acropolis, ITAT deleted the disputed addition for AY 2017-18, ruling in assessee's favor. .....

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