https://www.taxtmi.com/caselaws?id=450645 The ITAT Delhi allowed the assessee's appeal against additions made under sections 69A and 69C based on entries found in seized documents from a third party. The court held that the statement of a third party witness recorded during search could not be used adversely against the assessee without providing an opportunity for cross-examination, violating principles of natural justice. The HC precedent in SMC Share Brokers Ltd. supported this position. The additions were deemed unsustainable as they were based on mere suspicion and conjecture rather than legally sound evidence, with no corroborative documentation like bills or invoices to support the alleged transactions. en-us Thu, 07 Mar 2024 00:00:00 +0530 Fri, 08 Mar 2024 17:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450645 The ITAT Delhi allowed the assessee's appeal against additions made under sections 69A and 69C based on entries found in seized documents from a third party. The court held that the statement of a third party witness recorded during search could not be used adversely against the assessee without providing an opportunity for cross-examination, violating principles of natural justice. The HC precedent in SMC Share Brokers Ltd. supported this position. The additions were deemed unsustainable as they were based on mere suspicion and conjecture rather than legally sound evidence, with no corroborative documentation like bills or invoices to support the alleged transactions. Case-Laws Income Tax Thu, 07 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450645