Additions based on loose sheets/excel data seized during search – Assessee being a salaried employee with no business activity – No ownership or nexus of entries established – Entries found to be group financial projections and borrowings – No corroborative evidence or unexplained assets – Additions deleted.

15. [2025] 128 ITR(T) 368 (Chandigarh- Trib.) DCIT v. Kapil Romana A.Y.: 2017-18, 2018-19 AND 2019-20 DATE: 16.06.2025 Section: 68 r.w.s. 69C & 115BBE Additions based on loose sheets/excel data seized during search – Assessee being a salaried employee with no business activity – No ownership or nexus of entries established – Entries found to be group financial projections and borrowings – No corroborative evidence or unexplained assets – Additions deleted. FACTS A search and seizure operation was conducted in the case of the Homeland Group and the assessee, who was a salaried employee managing the financial affairs of the group. During the course of the search, certain loose papers and excel sheets titled “BTD-2011” were found containing details of credit limits, financial arrangements, and names of certain parties with amounts mentioned therein. The Assessing Officer treated such entries as representing unsecured loans and unexplained expenditure of the assessee and made additions under sections 68 and 69C read with section 115BBE, alleging that the assessee had raised unaccounted funds. On appeal, the Commissioner (Appeals) observed that the seized documents did not contain the name of the assessee and merely reflected financial details and projections relating to group entities. It was further noted that the ass