https://www.taxtmi.com/caselaws?id=461479 ITAT Mumbai dismissed Revenue's appeal challenging deletions of additions under sections 69A and 69C. The assessee was implicated based on documents and statements found during search at third party premises, not assessee's own premises. ITAT held that documents found at third party premises only raised suspicion requiring independent corroboration, which was absent. Transfer order relied upon by AO was insufficient independent evidence. Presumption under section 132(4A) applies only to person from whose possession documents are found, not third parties. CIT(A)'s deletion of additions was upheld as Revenue failed to establish direct link between assessee and seized materials through independent evidence. en-us Fri, 24 Jan 2025 00:00:00 +0530 Tue, 08 Apr 2025 18:56:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461479 ITAT Mumbai dismissed Revenue's appeal challenging deletions of additions under sections 69A and 69C. The assessee was implicated based on documents and statements found during search at third party premises, not assessee's own premises. ITAT held that documents found at third party premises only raised suspicion requiring independent corroboration, which was absent. Transfer order relied upon by AO was insufficient independent evidence. Presumption under section 132(4A) applies only to person from whose possession documents are found, not third parties. CIT(A)'s deletion of additions was upheld as Revenue failed to establish direct link between assessee and seized materials through independent evidence. Case-Laws Income Tax Fri, 24 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461479