https://www.taxtmi.com/caselaws?id=751081 ITAT Chennai dismissed revenue's appeal regarding additions made under section 153C based on search findings from mining group cases. The tribunal upheld CIT(A)'s decision that additions cannot be sustained solely on "dumb documents" - seized diary entries with abbreviated names lacking complete transaction details, purpose, or clear identity of parties involved. Without corroborative evidence, such entries cannot establish tax liability. The seized material from a third party's possession did not directly implicate the assessee, and additions based on presumptions, conjectures, or surmises are impermissible under established SC and HC precedents. en-us Wed, 03 Apr 2024 00:00:00 +0530 Fri, 23 May 2025 16:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751081 ITAT Chennai dismissed revenue's appeal regarding additions made under section 153C based on search findings from mining group cases. The tribunal upheld CIT(A)'s decision that additions cannot be sustained solely on "dumb documents" - seized diary entries with abbreviated names lacking complete transaction details, purpose, or clear identity of parties involved. Without corroborative evidence, such entries cannot establish tax liability. The seized material from a third party's possession did not directly implicate the assessee, and additions based on presumptions, conjectures, or surmises are impermissible under established SC and HC precedents. Case-Laws Income Tax Wed, 03 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751081