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    <title>2024 (4) TMI 450 - ITAT MUMBAI</title>
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    <description>Protective addition based on alleged over-invoicing of purchases was unsustainable where the foundation was a retracted statement, the cash found with the maker was assessed as his own undisclosed income, and the purchase references were linked to another concern rather than the assessee. The Revenue also failed to produce reliable corroborative evidence showing excess payment, cash flow-back, or the assessee&#039;s involvement, and the price-comparison exercise was found flawed and unsupported by tangible material. On these facts, the protective addition in the assessee&#039;s hands could not survive.</description>
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      <link>https://www.taxtmi.com/caselaws?id=751269</link>
      <description>Protective addition based on alleged over-invoicing of purchases was unsustainable where the foundation was a retracted statement, the cash found with the maker was assessed as his own undisclosed income, and the purchase references were linked to another concern rather than the assessee. The Revenue also failed to produce reliable corroborative evidence showing excess payment, cash flow-back, or the assessee&#039;s involvement, and the price-comparison exercise was found flawed and unsupported by tangible material. On these facts, the protective addition in the assessee&#039;s hands could not survive.</description>
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