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The ITAT held that additions based on documents recovered from third parties cannot be sustained against the assessee company absent direct linkage or corroborative evidence. Since no satisfaction was recorded by the AO under section 147 regarding the seized materials and no opportunity for cross-examination of third parties was granted, the additions on account of alleged unaccounted transactions and valuation discrepancies were deleted. The tribunal emphasized that documents found in possession of third parties pertain only to those persons and cannot bind the assessee without independent verification. Consequently, additions totaling over Rs. 3.46 crore confirmed by the CIT(A) were reversed. The reliance on digital data and valuation reports submitted by third parties was rejected due to lack of evidentiary foundation and legal satisfaction. The provisions of section 115BBE were also held inapplicable. The appeals by the assessee were allowed, and the revenue's appeals were dismissed on these grounds.
The ITAT held that additions based on documents recovered from third parties cannot be sustained against the assessee company absent direct linkage or corroborative evidence. Since no satisfaction was recorded by the AO under section 147 regarding the seized materials and no opportunity for cross-examination of third parties was granted, the additions on account of alleged unaccounted transactions and valuation discrepancies were deleted. The tribunal emphasized that documents found in possession of third parties pertain only to those persons and cannot bind the assessee without independent verification. Consequently, additions totaling over Rs. 3.46 crore confirmed by the CIT(A) were reversed. The reliance on digital data and valuation reports submitted by third parties was rejected due to lack of evidentiary foundation and legal satisfaction. The provisions of section 115BBE were also held inapplicable. The appeals by the assessee were allowed, and the revenue's appeals were dismissed on these grounds.
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