https://www.taxtmi.com/caselaws?id=448603 ITAT Chennai held that AO erroneously made additions u/s 69A for alleged on-money receipt on property sale. The addition was based solely on seized documents from third party showing cash transfer to Bangalore occurring 9 days after property registration, without any direct evidence linking cash to the assessee. ITAT ruled that suspicion cannot substitute evidence, citing SC precedent. Legal presumption u/s 132(4A) and 292C applies only to searched person, not third parties. Since seized material contained no reference to assessee's name or specific property, no adverse inference could be drawn. CIT(A)'s deletion of additions was upheld. en-us Fri, 19 Jan 2024 00:00:00 +0530 Tue, 23 Jan 2024 16:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448603 ITAT Chennai held that AO erroneously made additions u/s 69A for alleged on-money receipt on property sale. The addition was based solely on seized documents from third party showing cash transfer to Bangalore occurring 9 days after property registration, without any direct evidence linking cash to the assessee. ITAT ruled that suspicion cannot substitute evidence, citing SC precedent. Legal presumption u/s 132(4A) and 292C applies only to searched person, not third parties. Since seized material contained no reference to assessee's name or specific property, no adverse inference could be drawn. CIT(A)'s deletion of additions was upheld. Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448603