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    <description>An income addition based on an assessee&#039;s alleged involvement in a scam cannot be sustained where the assessee was named only at the FIR/investigation stage, was not sent up for trial, was not arraigned as an accused, and was neither tried nor convicted. The criminal record, including the Special Judge&#039;s certificate and judgment, confirmed that no criminal proceeding was pursued against the assessee. In the absence of any independent corroborative material showing actual involvement or receipt of undisclosed benefit, the basis for the estimated addition failed and the addition was deleted.</description>
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      <description>An income addition based on an assessee&#039;s alleged involvement in a scam cannot be sustained where the assessee was named only at the FIR/investigation stage, was not sent up for trial, was not arraigned as an accused, and was neither tried nor convicted. The criminal record, including the Special Judge&#039;s certificate and judgment, confirmed that no criminal proceeding was pursued against the assessee. In the absence of any independent corroborative material showing actual involvement or receipt of undisclosed benefit, the basis for the estimated addition failed and the addition was deleted.</description>
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