Shanti Prime Publication Pvt. Ltd.
Sec. 153A of income Tax Act, 1961— Assessment —It is true that the initial onus is upon the assessee as the said document was found from his possession but at the same time, some logical inference has to be drawn from the seized document which, in the present case are unable to draw and the said document can only be considered as a dumb document as the said document does not contain full details about the dates of payments and the recipient of the payments nor there is mention of any name of the employee, therefore, considering the nature of document and jotting/notings made thereon, no addition can be made on the basis of such dumb document and addition is, accordingly directed to be deleted. - PARAM DAIRY LTD. V/s ASSTT. CIT - [2020] 77 ITR (TRIB) 567 (ITAT-DELHI)