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The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of additions made under section 69C arising from a search under section 132, holding that the AO's findings were inconclusive and uncorroborated. The Tribunal found that alleged payments for transfers/postings were supported only by material seized from third parties and digital evidence, with no direct nexus established to the assessee and with denials by the assessee; requests for cross-examination were refused below. In these circumstances, and having regard to coordinate bench reasoning on identical facts, the ITAT concluded the additions could not be sustained and affirmed deletion by the CIT(A).
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of additions made under section 69C arising from a search under section 132, holding that the AO's findings were inconclusive and uncorroborated. The Tribunal found that alleged payments for transfers/postings were supported only by material seized from third parties and digital evidence, with no direct nexus established to the assessee and with denials by the assessee; requests for cross-examination were refused below. In these circumstances, and having regard to coordinate bench reasoning on identical facts, the ITAT concluded the additions could not be sustained and affirmed deletion by the CIT(A).
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