https://www.taxtmi.com/caselaws?id=756108 ITAT Bangalore allowed the appeal, deleting additions of Rs.50 lakhs made for alleged unaccounted cash receipts from students. The AO's addition was based solely on unsubstantiated loose sheets, Excel files, and statements recorded under section 132(4) without corroborative evidence. The tribunal held that seized materials were non-speaking documents requiring corroboration, and statements from students/parents were either denied or not properly cross-examined. No undisclosed assets were found during search, and physical cash matched books of account. The tribunal emphasized that suspicion cannot replace material evidence, and rebuttable presumptions under section 132(4) were successfully challenged by the assessee's denial and lack of conclusive proof. en-us Thu, 18 Jul 2024 00:00:00 +0530 Fri, 26 Jul 2024 21:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756108 ITAT Bangalore allowed the appeal, deleting additions of Rs.50 lakhs made for alleged unaccounted cash receipts from students. The AO's addition was based solely on unsubstantiated loose sheets, Excel files, and statements recorded under section 132(4) without corroborative evidence. The tribunal held that seized materials were non-speaking documents requiring corroboration, and statements from students/parents were either denied or not properly cross-examined. No undisclosed assets were found during search, and physical cash matched books of account. The tribunal emphasized that suspicion cannot replace material evidence, and rebuttable presumptions under section 132(4) were successfully challenged by the assessee's denial and lack of conclusive proof. Case-Laws Income Tax Thu, 18 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756108