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ITAT upheld the CIT(A)'s deletion of addition u/s 69B r.w.s. 115BBE in respect of alleged "on-money" for purchase of land. The Tribunal held that loose sheets and diaries seized from a third party, containing only dates, amounts and abbreviated names without identifying payer, payee, nature or purpose of transactions, were "dumb documents" lacking evidentiary value. The material was neither seized from the assessee nor in assessee's or vendors' handwriting, and no independent, corroborative evidence or actual money trail was brought on record. The AO's reliance on such uncorroborated documents and a subsequently retracted statement was held legally untenable. Consequently, the addition for unexplained investment was unsustainable, and the assessee's appeal was allowed.
ITAT upheld the CIT(A)'s deletion of addition u/s 69B r.w.s. 115BBE in respect of alleged "on-money" for purchase of land. The Tribunal held that loose sheets and diaries seized from a third party, containing only dates, amounts and abbreviated names without identifying payer, payee, nature or purpose of transactions, were "dumb documents" lacking evidentiary value. The material was neither seized from the assessee nor in assessee's or vendors' handwriting, and no independent, corroborative evidence or actual money trail was brought on record. The AO's reliance on such uncorroborated documents and a subsequently retracted statement was held legally untenable. Consequently, the addition for unexplained investment was unsustainable, and the assessee's appeal was allowed.
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