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(b) Sir Mohammed Yusuf & Anr. vs. D. & Anr. AIR 1968 112 42 (Bom); and

(c) Criminal Petition No. 265/1995, April, 1997 - L. K. Advani.

It is further submitted that uncorroborative entries in the books of accounts or documents do not establish their truthfulness and in this connection he laid emphasis on the contents of the document or book of account and truthfulness of the contents. It is emphasised that jotting in diary is held neither a book nor a document. Therefore, addition cannot be justified merely on the basis of seized papers. With reference to the decision of Tribunal in the case of ITO vs. W. D. Estates (P) Ltd. (supra) it was submitted that no addition could be made merely on the basis of a notorious fact that on-money is involved in property deals, particularly when the AO has not made any such allegation in the present case and no evidence was found during the course of search that any transaction entered into by the assessee is not disclosed by him.