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ITAT ruled against additions made under section 69 for alleged cash loans and notional interest. The additions were based solely on documents seized during third-party premises search and statements under section 132(4), which were later retracted claiming duress. Despite concurrent searches at appellant's premises, no incriminating evidence was found to support alleged cash transactions. The absence of promissory notes or other documentation for substantial loan amounts was deemed improbable. ITAT held that Assessing Officer failed to gather corroborative evidence beyond seized materials and third-party statements. The tribunal concluded additions for unexplained investments and notional interest were unsustainable without cogent evidence, ruling in appellant's favor.
ITAT ruled against additions made under section 69 for alleged cash loans and notional interest. The additions were based solely on documents seized during third-party premises search and statements under section 132(4), which were later retracted claiming duress. Despite concurrent searches at appellant's premises, no incriminating evidence was found to support alleged cash transactions. The absence of promissory notes or other documentation for substantial loan amounts was deemed improbable. ITAT held that Assessing Officer failed to gather corroborative evidence beyond seized materials and third-party statements. The tribunal concluded additions for unexplained investments and notional interest were unsustainable without cogent evidence, ruling in appellant's favor.
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