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    <title>2021 (7) TMI 767 - ITAT HYDERABAD</title>
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    <description>An addition for alleged on-money payment under section 69B is said to fail where the Revenue relies mainly on unauthenticated digital material and third-party statements without reliable corroboration. The Tribunal&#039;s reasoning, as reflected in the text, is that electronic evidence must have proper authentication and statutory certification, and that seized records or admissions by third parties do not by themselves establish unexplained investment against the assessee when no independent physical evidence, effective corroboration, or tested cross-examination material is produced. The governing principle stated is that suspicion, however strong, cannot replace proof, and the addition was deleted on that basis.</description>
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      <title>2021 (7) TMI 767 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=409925</link>
      <description>An addition for alleged on-money payment under section 69B is said to fail where the Revenue relies mainly on unauthenticated digital material and third-party statements without reliable corroboration. The Tribunal&#039;s reasoning, as reflected in the text, is that electronic evidence must have proper authentication and statutory certification, and that seized records or admissions by third parties do not by themselves establish unexplained investment against the assessee when no independent physical evidence, effective corroboration, or tested cross-examination material is produced. The governing principle stated is that suspicion, however strong, cannot replace proof, and the addition was deleted on that basis.</description>
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      <pubDate>Thu, 15 Jul 2021 00:00:00 +0530</pubDate>
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