https://www.taxtmi.com/caselaws?id=751130 ITAT Chennai dismissed revenue appeals and assessee's cross-objections regarding additions based on seized materials from third-party premises. The tribunal upheld CIT(A)'s deletion of additions, finding seized documents were "dumb documents" lacking complete information to establish assessee's involvement. The acronym "HM" found on loose sheets could not be conclusively linked to the assessee without corroborative evidence. Statement recorded under section 132(4) was retracted and had no standalone evidentiary value. Presumption under section 132(4A) applies only to searched persons, not third parties. Court emphasized need for independent corroborative evidence for loose sheets not forming part of regular books of accounts. en-us Wed, 03 Apr 2024 00:00:00 +0530 Sat, 06 Apr 2024 09:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751130 ITAT Chennai dismissed revenue appeals and assessee's cross-objections regarding additions based on seized materials from third-party premises. The tribunal upheld CIT(A)'s deletion of additions, finding seized documents were "dumb documents" lacking complete information to establish assessee's involvement. The acronym "HM" found on loose sheets could not be conclusively linked to the assessee without corroborative evidence. Statement recorded under section 132(4) was retracted and had no standalone evidentiary value. Presumption under section 132(4A) applies only to searched persons, not third parties. Court emphasized need for independent corroborative evidence for loose sheets not forming part of regular books of accounts. Case-Laws Income Tax Wed, 03 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751130