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Issues: Whether the addition made as undisclosed income on the basis of newspaper reports alleging receipt of USD 30 million on sale of the business/domain name was sustainable.
Analysis: The assessment was founded principally on a news article and related press reports, without independent verification or corroborative material. The record showed distinct transactions of share transfer and later transfer of the domain and brand assets, and the newspaper report was not shown to be proved by evidence aliunde. A newspaper item is only hearsay and cannot by itself establish taxable receipt or justify an addition in assessment in the absence of supporting evidence.
Conclusion: The addition was not sustainable and the deletion made by the first appellate authority was upheld in favour of the assessee.
Final Conclusion: The revenue's challenge failed because the impugned assessment could not rest on an unverified media report without corroboration.
Ratio Decidendi: A newspaper report, being hearsay, cannot form the sole basis for a tax addition unless its contents are independently verified and supported by admissible evidence.