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    <title>2020 (12) TMI 254 - ITAT KOLKATA</title>
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    <description>For completed assessments under section 153A, additions are sustainable only when founded on tangible incriminating material found during the search; third-party statements, post-search enquiries, or a different view of material already on record do not qualify, so the additions for unabated years were deleted. On the merits of the unsecured loans and related interest, the assessee supported the transactions with confirmations, PAN, audited accounts, bank records, MCA details and TDS evidence, and mere non-service of summons or uncorroborated third-party statements was insufficient to treat the credits as unexplained. The additions under sections 68 and 69C were therefore deleted and the appeals were allowed.</description>
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      <title>2020 (12) TMI 254 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=401455</link>
      <description>For completed assessments under section 153A, additions are sustainable only when founded on tangible incriminating material found during the search; third-party statements, post-search enquiries, or a different view of material already on record do not qualify, so the additions for unabated years were deleted. On the merits of the unsecured loans and related interest, the assessee supported the transactions with confirmations, PAN, audited accounts, bank records, MCA details and TDS evidence, and mere non-service of summons or uncorroborated third-party statements was insufficient to treat the credits as unexplained. The additions under sections 68 and 69C were therefore deleted and the appeals were allowed.</description>
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