Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
ITAT held that additions based solely on third party digital material (pen drive/excel files) and statements, without cash vouchers, receipts or documents linking the assessee, required independent corroboration by the Revenue and an opportunity for the assessee to confront or cross examine deponents; the Assessing Officer failed to produce corroborative evidence or comparable transactions and denied confrontation, breaching principles of natural justice. Consequently the Tribunal found the additions unsustainable and deleted them, allowing the appeals for the relevant assessment years.
ITAT held that additions based solely on third party digital material (pen drive/excel files) and statements, without cash vouchers, receipts or documents linking the assessee, required independent corroboration by the Revenue and an opportunity for the assessee to confront or cross examine deponents; the Assessing Officer failed to produce corroborative evidence or comparable transactions and denied confrontation, breaching principles of natural justice. Consequently the Tribunal found the additions unsustainable and deleted them, allowing the appeals for the relevant assessment years.
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