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    <title>2023 (9) TMI 429 - ITAT SURAT</title>
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    <description>Unauthenticated third-party loose papers and an unsigned memorandum of understanding, without corroborative evidence linking the assessee to the entries, were held insufficient to sustain additions for unexplained investment or unexplained cash receipts and payments. The memorandum did not show payment by the assessee, and the figures were based on extrapolation rather than direct proof. Likewise, coded references in seized material were explained by the third party as relating to another person, and no independent investigation tied the assessee to the alleged transactions. On that basis, the additions were deleted and the revenue&#039;s challenge failed.</description>
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    <pubDate>Wed, 06 Sep 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=442807</link>
      <description>Unauthenticated third-party loose papers and an unsigned memorandum of understanding, without corroborative evidence linking the assessee to the entries, were held insufficient to sustain additions for unexplained investment or unexplained cash receipts and payments. The memorandum did not show payment by the assessee, and the figures were based on extrapolation rather than direct proof. Likewise, coded references in seized material were explained by the third party as relating to another person, and no independent investigation tied the assessee to the alleged transactions. On that basis, the additions were deleted and the revenue&#039;s challenge failed.</description>
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      <pubDate>Wed, 06 Sep 2023 00:00:00 +0530</pubDate>
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