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    <title>2018 (1) TMI 1100 - ITAT RAIPUR</title>
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    <description>Additions under deeming provisions in search assessments cannot rest on untested statements, suspicion, or loose papers without corroborative material establishing a direct nexus to undisclosed income. Cash deposits were deleted where a confirmation showed the bank account belonged to a third party and the Revenue did not supply the relied-upon statement for cross-examination. The major part of the household-expense estimate under section 69C was also reduced because the factual basis on family size was not proved. Alleged excess stock of gold and silver, and rough loose-paper entries, were likewise rejected for want of reliable incriminating evidence. The appellate deletions were upheld and the Revenue&#039;s appeals were dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=354364</link>
      <description>Additions under deeming provisions in search assessments cannot rest on untested statements, suspicion, or loose papers without corroborative material establishing a direct nexus to undisclosed income. Cash deposits were deleted where a confirmation showed the bank account belonged to a third party and the Revenue did not supply the relied-upon statement for cross-examination. The major part of the household-expense estimate under section 69C was also reduced because the factual basis on family size was not proved. Alleged excess stock of gold and silver, and rough loose-paper entries, were likewise rejected for want of reliable incriminating evidence. The appellate deletions were upheld and the Revenue&#039;s appeals were dismissed.</description>
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