https://www.taxtmi.com/caselaws?id=774043 ITAT Mumbai held that CIT(A) cannot improve upon AO's case by changing the basis of additions from section 68 to 69A without issuing show cause notice or providing hearing opportunity to the assessee. The tribunal deleted additions under section 69A noting no physical money was found, mere confession during search lacks evidentiary value without corroborative evidence, and allowed expenses against commission income. Regarding excess cash deposits, the tribunal found sources adequately explained through tuition fees and bank withdrawals, directing deletion of all additions. en-us Tue, 27 May 2025 00:00:00 +0530 Wed, 02 Jul 2025 08:42:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774043 ITAT Mumbai held that CIT(A) cannot improve upon AO's case by changing the basis of additions from section 68 to 69A without issuing show cause notice or providing hearing opportunity to the assessee. The tribunal deleted additions under section 69A noting no physical money was found, mere confession during search lacks evidentiary value without corroborative evidence, and allowed expenses against commission income. Regarding excess cash deposits, the tribunal found sources adequately explained through tuition fees and bank withdrawals, directing deletion of all additions. Case-Laws Income Tax Tue, 27 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774043