https://www.taxtmi.com/caselaws?id=765854 ITAT Pune held that additions based on extrapolation of alleged on-money receipts from shop sales were unjustified. The tribunal found that statements recorded under section 133A lack evidentiary value as they cannot be taken on oath, citing Madras HC and Kerala HC precedents. The sales manager denied receiving on-money and was not confronted with discrepancies. No buyers were examined during search or assessment proceedings, no cash or valuables were found, and no relationship between buyers and assessee was established. Without proper corroboration or investigation, extrapolation across three assessment years was deemed improper. Appeals were partly allowed. en-us Fri, 07 Feb 2025 00:00:00 +0530 Tue, 11 Feb 2025 07:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765854 ITAT Pune held that additions based on extrapolation of alleged on-money receipts from shop sales were unjustified. The tribunal found that statements recorded under section 133A lack evidentiary value as they cannot be taken on oath, citing Madras HC and Kerala HC precedents. The sales manager denied receiving on-money and was not confronted with discrepancies. No buyers were examined during search or assessment proceedings, no cash or valuables were found, and no relationship between buyers and assessee was established. Without proper corroboration or investigation, extrapolation across three assessment years was deemed improper. Appeals were partly allowed. Case-Laws Income Tax Fri, 07 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765854