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    <title>2022 (5) TMI 1479 - ITAT SURAT</title>
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    <description>An addition based on a third-party seized saudha chithi was unsustainable because the document did not identify the assessee, was unsupported by corroborative evidence, and functioned only as a dumb document. Reliance on third-party statements also failed when the assessee was denied effective cross-examination, contrary to natural justice. Capital gains could not be taxed in the year under appeal because no registered transfer had been executed, possession remained with the assessee, and receipt of consideration was not proved. The Revenue&#039;s challenge was therefore rejected.</description>
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      <description>An addition based on a third-party seized saudha chithi was unsustainable because the document did not identify the assessee, was unsupported by corroborative evidence, and functioned only as a dumb document. Reliance on third-party statements also failed when the assessee was denied effective cross-examination, contrary to natural justice. Capital gains could not be taxed in the year under appeal because no registered transfer had been executed, possession remained with the assessee, and receipt of consideration was not proved. The Revenue&#039;s challenge was therefore rejected.</description>
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