IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER ITA No. 882 to 887/Bang/2025 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Assessee by : Shri Shivprasad Reddy, AR &

Shri B.S Balachandran, Advocate Revenue by : Shri N Balusamy, JCIT (DR) Date of hearing : 17.12.2025 Date of Pronouncement : 02.02.2026

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These 6 appeals, filed by the assessee against the separate order of the learned Commissioner of Income Tax (Appeal) (hereafter- learned CIT(A)) under the provision of section 259 of the Income Tax Act, 1961 (hereafter- the Act), were heard together.

First, we take up ITA No. 882/Bang/2025 pertaining to AY

2010-11

2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 7 and sub-grounds thereunder, which we, for the sake of brevity, are not inclined to reproduce here.

3. First, we proceed to adjudicate the issue raised through Ground No. 3 of the appeal pertaining to the merit of the addition of Rs. 1.12 crore made on account of alleged undisclosed income.

4. The brief facts of the case are that the assessee, an individual, filed its ROI declaring a total income of Rs. 3,20,995/- only. The assessee is deriving income from agricultural activities and interest income from money lending activities. A search and seizure action u/s 132 was conducted in the case of M/s Srinivasa Trust on 23.09.2016 i.e. AY 2017-18 and on the same day, the residential premises of the assessee was also searched in this connection, and materials/ documents viz. loose sheets were found at the premises of the assessee. The said document was of the nature of interest earned from money lending activities. The AO made an addition u/s 69 of the Act on account of unexplained money to the tune of Rs. 1,12,00,000 (Rs. 1 Crore principal and Rs. 12 Lakhs interest thereon) based on page 102 of A/ST/KKR/01.

5. Aggrieved by the action of AO, the assessee preferred an appeal before the Ld. CIT (A)

6. Before the Ld. CIT(A), the assessee submitted that the purported amount as per the seized material pertains to FY 2008-09 and therefore can be brought to tax for AY 2009-10 only, if at all required and not to the AY 2010-11. However, the Ld. CIT(A) dismissed the plea of assessee citing the reason that the amount relates to the period October 2009 which represents FY 2009-10 and thus pertains to AY 2010-11.

7. Aggrieved by the order of the Ld. CIT(A), the assessee has preferred an appeal before us.

8. The Ld. AR before us submitted that the addition made by the Assessing Officer is based solely on a seized document, which does not belong to the assessee. This position was clearly explained by the assessee during the course of search itself and consistently thereafter. Despite this, the authorities below proceeded to rely upon the said document without establishing any nexus between the contents of the document and the assessee.

8.1 The learned AR further submitted that the seized document is a dumb document. It is neither in the handwriting of the assessee nor does it contain any basic identifying particulars such as the names of parties, dates, nature of transaction, or confirmation of receipt or payment. Such an uncorroborated document, by itself, cannot form the basis of an addition.

8.2 It was contended that there is no evidence whatsoever of transfer of funds. The Revenue has not brought on record any proof of receipt of money by the assessee, such as bank entries, cash flow, confirmation from any lender, or any other corr