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    <title>2024 (4) TMI 348 - ITAT CHENNAI</title>
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    <description>ITAT Chennai dismissed revenue&#039;s appeals challenging CIT(A)&#039;s deletion of undisclosed income additions under s.153C assessment. Seized materials from third party contained name &quot;OPS Ramesh&quot; but lacked complete information linking it to assessee. AO&#039;s inference that assessee received payments from M/s SRS Mining was based on wild allegations without corroborative evidence. Statements recorded under s.132(4) were retracted and had no standalone evidentiary value. Statutory presumption under s.132(4A) applies only to searched person, not third parties. Court held seized documents were dumb documents insufficient to establish assessee&#039;s receipt of noted payments without independent corroborative evidence.</description>
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    <pubDate>Fri, 05 Apr 2024 00:00:00 +0530</pubDate>
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      <title>2024 (4) TMI 348 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=751167</link>
      <description>ITAT Chennai dismissed revenue&#039;s appeals challenging CIT(A)&#039;s deletion of undisclosed income additions under s.153C assessment. Seized materials from third party contained name &quot;OPS Ramesh&quot; but lacked complete information linking it to assessee. AO&#039;s inference that assessee received payments from M/s SRS Mining was based on wild allegations without corroborative evidence. Statements recorded under s.132(4) were retracted and had no standalone evidentiary value. Statutory presumption under s.132(4A) applies only to searched person, not third parties. Court held seized documents were dumb documents insufficient to establish assessee&#039;s receipt of noted payments without independent corroborative evidence.</description>
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      <pubDate>Fri, 05 Apr 2024 00:00:00 +0530</pubDate>
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