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    <title>2014 (11) TMI 1123 - ITAT PUNE</title>
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    <description>An addition under section 69 based on seized papers from a third party was deleted because the assessee&#039;s identity and nexus with the entries were not proved. The Tribunal found that the documents contained inconsistent references, did not clearly identify the assessee, and were unsupported by any promissory note, admission, security, or other corroborative material. It also noted that the assessee denied the transaction and was not granted cross-examination of the person from whose premises the material was seized. On these facts, the addition could not rest on suspicion or inference alone, and the Revenue failed to establish the alleged investment with reliable evidence.</description>
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    <pubDate>Fri, 28 Nov 2014 00:00:00 +0530</pubDate>
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      <title>2014 (11) TMI 1123 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=192887</link>
      <description>An addition under section 69 based on seized papers from a third party was deleted because the assessee&#039;s identity and nexus with the entries were not proved. The Tribunal found that the documents contained inconsistent references, did not clearly identify the assessee, and were unsupported by any promissory note, admission, security, or other corroborative material. It also noted that the assessee denied the transaction and was not granted cross-examination of the person from whose premises the material was seized. On these facts, the addition could not rest on suspicion or inference alone, and the Revenue failed to establish the alleged investment with reliable evidence.</description>
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      <pubDate>Fri, 28 Nov 2014 00:00:00 +0530</pubDate>
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