No addition can be made on the basis of “Dumb documents” seized during a search action:

If documents seized during a Search action are found to be “Dumb documents”, then in absence of any evidence that such documents unearthed a concealed business activity of the assessee, addition made on the basis of the same by placing reliance on S.132(4A) remains un-corroborated and needs to be deleted.If an addition is to be made on the basis of seized documents, then it must be supported by “some identification” having nexus with unaccounted business activity of the assessee. It was further held that S.132(4A) uses the words “may presume” which imply that such presumption is rebuttable.

[DHARMENDRASINH R. WAGHELA (TAX APPEAL NO.1539 of 2011 - GHC]