Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
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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