JUDGMENT : This appeal is directed under section 260-A of the Income Tax Act, 1961 against the order passed by Income Tax Appellate Tribunal, Jabalpur in case IT(SS)ANo.6/Jab/07, block period 1.4.1995 to 24.1.2002, affirming order passed by the Income Tax Commissioner Annexure A-2 dated 12.12.2006 in case Appeal No. CIT (A)-II, Bhopal (CHD)/IT-74/2003-04, in respect of deletion of an amount of Rs.60,23,687/- which was added by the Assessing Officer as an undisclosed income of the respondent assessee. Learned counsel for appellant submitted that Income Tax Appellate Tribunal, erred in affirming the order passed by the Commissioner of Income Tax, while it was the duty on the part of Income Tax Appellate Tribunal to inquire into the matter. To appreciate the aforesaid contention, it would be appropriate if para 6 and 6.1 of the order passed by Income Tax Appellate Tribunal are referred for ready reference, which reads as under :- "6. The next issue is with regard to addition of Rs.60,23,687/- made by the Assessing Officer on account of investments in Gurunanak General Stores which was deleted by the CIT(A). This addition of Rs.60,23,687/- consists of two additions of Rs.60,02,457/- and Rs.21,230/-. 6.1 The learned AR for the assessee explained before the CIT(A) the nature and content of the loose paper which do not carry specifically as to which transactions they relate. Some of these entries relate to household expenses, electricity bill, and telephone bill and the expenditure relating to Shri P.S. Bedi, Shri K.S. Bedi without indicating the amount incurred in respect of different heads of expenses. The loose paper marked as Annexure A-2/21 reflects some expenses on certain date without indicating the heads of expenses. The entered amount of Rs.93,351/- is found in Annexure-2/21, page 1 which was the total of the expenditure on a particular date beginning from 06/04/2000 to 25/04/2000 but the total of Rs.7,01,190/- shown in page 2 was based on the figures in respect of different items without the mention of the amount of expenditure. There was some amount noted in page 3 without mentioning nature of such expenses. Page 4 of the seized document A-2/24 did not indicated as to which figure has led to total at Rs.52,07,916/-. These papers were seized from the business premises of M/s Gurunanak General Stores, a partnership firm in which the assessee is not a partner. There was some amount noted in page 3 without mentioning nature of such expenses. Page 4 of the seized document A-2/24 did not indicated as to which figure has led to total at Rs.52,07,916/-. These papers were seized from the business premises of M/s Gurunanak General Stores, a partnership firm in which the assessee is not a partner. The Assessing Officer was told during the assessment proceedings of Gurunanak General Stores that these loose papers relate to Shri P.S. Bedi and the Assessing Officer has, therefore, concluded on the basis of this statement that the amount indicated in the loose sheets do not relate to M/s Gurunanak General Stores and consequently on the basis of such statement the Assessing officer has proceeded to tax these amounts in the hands of the assessee without confronting all those entries to the assessee at the time of the assessment proceedings. So the Assessing Officer has not raised any query regarding the nature and content of the loose paper during the assessment proceedings of the assessee and, therefore, the assessee was denied the opportunity to explain at the assessment stage. The nothings in the seized documents do not lead to any interference that the assessee had entered into any such transaction because there was no corroborative evidence regarding anyone of these entries so as to lead to the interference that the assessee had incurred such expenditure. According to CIT(A) the loose papers and documents cannot be construed as books of accounts regularly kept in the course of the business. It was observed on the perusal of the loose papers that some of these expenses relate to expenses incurred on telephone, electricity, household in respect of Shri P.S.Bedi and Shri K.S.Bedi as is evident from page 2 of Annexure A-2/21 but the total of this page was not shown at Rs.7,01,190/-. It was arrived at without mentioning the amount of expenses on different heads and there was absolutely any narration of the expenditure with any specific date in respect of the amount of Rs.52,07,916/- vide page 4 of Annexure A-2/21. There was no seized loose paper leading to the presumption that the assessee has incurred expenses of such a magnitude. The loose sheets of paper do not indicate that the amount was actually incurred by the assessee. There was no seized loose paper leading to the presumption that the assessee has incurred expenses of such a magnitude. The loose sheets of paper do not indicate that the amount was actually incurred by the assessee. There was no intrinsic value of the loose sheet provided the entries were not corroborated by any other evidence. The entries reflected in the seized document also do not indicate that there was any investment that had been made either in movable or immovable property or the investment made in some business. The Assessing officer has presumed on the basis of such noting in the loose paper that the expenditure relate to the assessee without corroborating the same with cogent reasoning. Accordingly, the CIT(A) was justified in deleting the addition which was not based on cogent reasoning. Same needs no interference from our side. We uphold the same." Before considering the contention of appellant, it would be appropriate to state some facts of the case. A search was made in the premises of M/s Guru Nanak General Stores, Chhindwara. In the premises 3 loose sheets were found in which total expenditure of Rs.60,02,457/- by P.S.Bedi was found. When the proceedings were initiated against M/s Guru Nanak General Stores, it was stated by the said assessee that these documents will be explained by P.S.Bedi and as they did not belong to him, the Assessing Officer while considering this aspect had not made any addition of the amount in the assessment of M/s Guru Nanak General Stores. By order Annexure A-1 directed addition of said income in the income of respondent assessee. For ready reference relevant portion of Annexure A-1 is referred :- "In the course of scrutiny, it was seen that a number of seized papers reveal details of liquor trade as under. Annexure no. Page No. Sale amount A-8 8 20,000/- A-16 1 24,050/- Total 44,050/- The facts were confronted with the assessee. He admitted that he had been engaged in the illegal trade of liquor in this year also and all those entries were related to his illegal trade business for financial year 2000-01. As has been discussed in above paras, the assessee has not maintained any accounts, whatsoever, in respect of his liquor trade and considering the illegality of the business, income earned from said business is taken to be 7% of total sale which works out to Rs.3,083/-. As has been discussed in above paras, the assessee has not maintained any accounts, whatsoever, in respect of his liquor trade and considering the illegality of the business, income earned from said business is taken to be 7% of total sale which works out to Rs.3,083/-. The amount involved in the business works out to Rs.3,414/- [1/12 (44,050 - 3,083)]. Thus, the total undisclosed income from the illegal sale of liquor business works out to Rs.6,497/-. In the course of scrutiny, a paper out of seized documents, bearing no.A-4/40 revealed that the assessee had made payment of Rs.21,230/- to various persons in the year under consideration. When confronted, the assessee could not offer any satisfactory explanation of the said payments. Hence, considering the said payments as unexplained expenses, the same is added to the total undisclosed income of the assessee. On verification of the documents seized from M/s Gurunanak General Stores, Chhindwara following investment/expenditure found to be made by the assessee as under -Annexure A-2/21 page 1 - Expenduture by P.S.Bedi from 93,351 6.4.2000 to 25.4.2000 Annexure A-2/21 page 2 & 3 - Expenditure by P.S. Bedi from 2.10.2000 to 31.10.2000 and 29.12.2000 to 31.12.2000 7,01,190 Annexure A-2/21 page 4 Expenditure by P.S. Bedi from April to December 2000 52,07,916,Total 60,02,916 In the enclosure submitted alongwith the reply on 9.1.2004 in the case of M/s Gurunanak General Stores, Chhindwara it has been stated that the above entries shall be explained in the case of Shri Prithpal Singh Bedi. But these entries have not been explained in the case of assessee. Therefore, above expenditure of Rs.60,02,457/-was out of undisclosed income of assessee. In this way, total income of the assessee for the year under consideration comes to Rs.60,30,184/-." In this case, it is not in dispute that the respondent/assessee has not admitted the aforesaid documents. The aforesaid documents were not found in the premises of assessee and there is no finding by any of the authority that there was any connection between the respondent and M/s Guru Nanak General Stores. In absence of which when these documents were specifically denied by respondent/assessee, and in absence of any incriminating evidence, both the authorities have found that there is no connection of these documents with the respondent assessee. It is a finding of fact recorded by the Commissioner of Income Tax and affirmed by Income Tax Appellate Tribunal. In absence of which when these documents were specifically denied by respondent/assessee, and in absence of any incriminating evidence, both the authorities have found that there is no connection of these documents with the respondent assessee. It is a finding of fact recorded by the Commissioner of Income Tax and affirmed by Income Tax Appellate Tribunal. In absence of any material, no error is found in the impugned order. This appeal is found without merit and is dismissed at admission stage, with no order as to costs.