ITAT Held Additions Based on Excel Sheets and Statements Without Corroborative Evidence Cannot Sustain Section 69 Proceedings :

The Income Tax Appellate Tribunal (ITAT), Agra has deleted unexplained investment additions of Rs 30 lakh and Rs 97 lakh made under Section 69 of the Income Tax Act, holding that the additions were not supported by any cogent and convincing evidence.

The appeals were filed by Ashok Singh Yadav against orders of the CIT(A) confirming additions made during reassessment proceedings for Assessment Years 2020-21 and 2021-22. For A.Y. 2020-21, the assessee had declared total income of Rs 6,28,870. Information was received by the Income Tax Department alleging that he had paid Rs 30 lakh in cash as on-money towards purchase of immovable property from the Omaxe Group.

A search under Section 132 was conducted at various premises of the Omaxe Group on March 14, 2022. During the search, certain evidence, including hard disks containing Excel files, was seized. Statements of the President and employees of the Omaxe Group were also recorded under Section 131(1A). According to the department, the seized Excel data indicated that the assessee had made an unaccounted cash investment in the property. Consequently, reassessment proceedings were initiated under Section 147 and notice under Section 148 was issued.

The AO treated Rs 30 lakh as unexplained investment under Section 69 of the Act. The CIT(A) subsequently upheld the addition.

Before the Tribunal, the assessee submitted that no cash payment had ever been made to the Omaxe Group and that payments towards the property were made only through banking channels.

The assessee also relied upon a confirmation letter dated October 31, 2025, issued by the Omaxe Group. The confirmation stated that during F.Y. 2019-20, the property booked by the assessee had resulted in receipt of Rs 1,51,000 through RTGS from Ashok Singh Yadav and that no other amount had been received either in cash or through banking channels.

The Tribunal allowed both ITA Nos. 513 & 514/Agr/2026 and set aside the orders, thereby deleting the additions made under Section 69 of the Income Tax Act.