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Addition under section 69 raised on a protective basis was set aside where seized third party material and statements did not explicitly prove cash 'on money' payments and the assessee denied such payments; ITAT held that reliance on limited third party evidence without corroboration is insufficient to attribute payments to the assessee. The tribunal also noted that a substantive addition against the closely connected brother had been deleted on merits by the first appellate authority, and therefore the protective addition against the assessee could not survive; appeal allowed.
Addition under section 69 raised on a protective basis was set aside where seized third party material and statements did not explicitly prove cash 'on money' payments and the assessee denied such payments; ITAT held that reliance on limited third party evidence without corroboration is insufficient to attribute payments to the assessee. The tribunal also noted that a substantive addition against the closely connected brother had been deleted on merits by the first appellate authority, and therefore the protective addition against the assessee could not survive; appeal allowed.
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