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    <title>2014 (11) TMI 691 - ITAT DELHI</title>
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    <description>Unexplained cash additions based solely on seized material recovered from a third party could not be sustained where the documents were not found from the assessee, the third party denied authorship and any cash or commission arrangement, and no corroborative evidence emerged from the assessee&#039;s premises or records. The Tribunal held that the search presumption applies only against the person from whose possession the material is found and remains rebuttable; it cannot be extended to a third party without independent supporting evidence. Loose papers by themselves were also treated as insufficient proof of undisclosed transactions, so the additions were deleted.</description>
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    <pubDate>Fri, 18 Jul 2014 00:00:00 +0530</pubDate>
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      <title>2014 (11) TMI 691 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=253374</link>
      <description>Unexplained cash additions based solely on seized material recovered from a third party could not be sustained where the documents were not found from the assessee, the third party denied authorship and any cash or commission arrangement, and no corroborative evidence emerged from the assessee&#039;s premises or records. The Tribunal held that the search presumption applies only against the person from whose possession the material is found and remains rebuttable; it cannot be extended to a third party without independent supporting evidence. Loose papers by themselves were also treated as insufficient proof of undisclosed transactions, so the additions were deleted.</description>
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      <pubDate>Fri, 18 Jul 2014 00:00:00 +0530</pubDate>
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