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Issues: Whether additions towards alleged on-money in respect of purchase of a shop, made in proceedings under section 153C on the basis of a third-party statement and an Excel sheet found during search, could be sustained without supplying the material to the assessee, bringing independent corroboration on record, or allowing cross-examination.
Analysis: The additions were founded primarily on a statement recorded during search and an alleged Excel sheet said to contain details of on-money receipts. The assessee was not provided a copy of the Excel sheet, the assessment order did not reproduce the relevant entries or date-wise linkage, and no independent evidence was brought on record to establish actual payment by the assessee. The Tribunal also noted the consistent view taken in similar Rubberwala Group matters that a third-party statement and uncorroborated digital data, by themselves, are insufficient where the assessee denies the payment and is denied an opportunity to test the evidence through cross-examination.
Conclusion: The additions could not be sustained and were deleted. The issue was decided in favour of the assessee.
Ratio Decidendi: An addition based on third-party material cannot be sustained unless the material is confronted to the assessee, supported by independent corroboration, and tested through cross-examination where sought.
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