Unauthenticated Excel Sheets and Emails Sent by Lenders deemed "Dumb Documents" for interest Addition: ITAT quashes order [Read Order]
The tribunal ruled that unauthenticated material did not constitute an admission by the assessee, particularly when authored by third parties and not confronted to the taxpayer during proceedings.
![Unauthenticated Excel Sheets and Emails Sent by Lenders deemed Dumb Documents for interest Addition: ITAT quashes order [Read Order]](https://images.taxscan.in/h-upload/2026/01/01/2116429-unauthenticated-excel-sheets-emails-sent-lenders-deemed-dumb-documents-interest-addition-itat-quashes-order-taxscan.webp "Unauthenticated Excel Sheets and Emails Sent by Lenders deemed Dumb Documents for interest Addition: ITAT quashes order [Read Order]")
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) held that loose papers, printouts, or emails not forming part of the assessee’s regular books and lacking independent corroboration were merely dumb documents and cannot justify additions. It quashed a series of assessment orders. Orris Infrastructure Pvt. Ltd. (assessee) faced search and seizure actions under Section 132...
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) held that loose papers, printouts, or emails not forming part of the assessee’s regular books and lacking independent corroboration were merely dumb documents and cannot justify additions. It quashed a series of assessment orders.
Orris Infrastructure Pvt. Ltd. (assessee) faced search and seizure actions under Section 132 of the Income Tax Act. The Assessing Officer (AO) made significant additions based on allegations of unaccounted interest expenditure paid to lenders such as U.K. Paints, Shahi Group, and Span Group.
These additions were primarily founded on emails with Excel attachments retrieved from the assessee’s computer, diaries and statements seized from third-party premises (U.K. Paints Group) and calculations suggesting interest was paid at dual rates one through cheque (accounted) and another in cash unaccounted.
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Aggrieved by the AO’s order, the assessee appealed to the Commissioner of Income Tax (Appeals) [CIT(A)]. The CIT(A) restricted the additions to ₹13.41 crores. Aggrieved by the CIT(A)’s, both the assessee and the Revenue filed cross-appeals before the ITAT.
The assessee argued that for the completed assessment years 2008-09 to 2011-12, no incriminating material was found at their own premises to justify reopening the assessments.
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The two-member bench comprising Mahavir Singh (Vice President) and Krinwant Sahay (Accountant Member) examined the nature of the evidence relied upon by the Revenue and the assessee’s contention.
The bench observed that the emails and excel files were authored by lender-side individuals like Rajneesh Gupta of U.K. Paints and K.K. Gautam of Span Group rather than the assessee.
The tribunal observed that the attached files were unsigned, unauthenticated, and did not form part of the statutory records of either the assessee or the third parties. It further observed that there was no independent evidence or cross-examination of the senders to confirm actual cash payments.
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It further observed that the ITAT had already deleted the alleged cash interest income in the hands of the lenders (U.K. Paints and Span Holdings) in separate proceedings. The appeals of the assessee were allowed, while the Revenue's appeals were dismissed.
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Orris Infrastructure Pvt.Ltd vs Assistant Commissioner of Income Tax , 2025 TAXSCAN (ITAT) 2250 , ITA Nos.2698/Del/2017 , 18 December 2025 , S.K. Tulsiyan , Monika Singh, CIT-DR.