addition of ` 91,770/-. These are aggregates of
various figures scribbled on loose slips of torn papers found during the
search added to the income ... within the prescribed limits. However, some loose
slips of torn papers containing scribblings were found and seized. Block
return was filed declaring nil undisclosed income
assessee's explanation at the first instance was that the scribblings as made represent membership deposits which work ... membership. There are further scribbles to the tune of Rs. 26,000 and Rs. 11,000. A sum of Rs. 2,31,000 has been
been able to conclusively establish nexus of
undisclosed income with scribbled amounts on loose sheets of
seized papers.
6) It is in the above background ... made the addition by taking up
the figures of 80 lakhs scribbled on the loose sheet of paper
and treated the same as undisclosed investment
appellant submitted the following:
"I informed search/survey officer that scribbling in diary of
my wife Smt. Sharda Taneja.
1. Dumb documents ... contemplating to buy
or construct and I may require funds.
4. Name scribbled or amount was my imagination.
5. I made while enquiries
debts and assets lying outside India. This is indicated from the following scribbling appearing in photostat copy of the assessee's statement of assessable ... assessee suo moto filed a photostat scribbling together with purported revised return of net wealth for the assessment year 1973-74 disclosing the deposit
confirming the arbitrary additions made by Assessing Officer on the
basis of scribblings in loose/dumb papers, seized & marked as
Annexure A-l page ... confirming the arbitrary additions made by Assessing
Officer on the basis of scribblings in loose/dumb papers, seized &
marked as Annexure A-l page
confirming the arbitrary additions made by Assessing Officer on the
basis of scribblings in loose/dumb papers, seized & marked as
Annexure A-l page ... confirming the arbitrary additions made by Assessing
Officer on the basis of scribblings in loose/dumb papers, seized &
marked as Annexure A-l page
stated that assessee
has explained each and every data/figure/scribbling on the
4
ITA NOS. 3334 & 3419/DEL/2011
seized documents. He further ... search operations
at the premises of Mr.Gurbax Singh in which
scribbling were alleged to be pertaining to the
assessee/appellant.
3. Assessee received
being aggregate of various figures scribbled on
loose slips which were found and seized during the course of search,
therefore, this ground pertaining to mixed ... being aggregate of various
figures scribbled on loose slips, found and seized during the
course of search."
5. Briefly stated the facts giving rise
Noting cannot be said to be any material as it was mere scribble. He
therefore, submitted the addition of sum of Rs. 5 crores itself ... book stating that
the noting on the said page are of the scribbling and do not represent
any income. He submitted that the same could
