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    <description>An addition for alleged undisclosed income could not be sustained where it rested solely on an image recovered from a third party&#039;s mobile phone, with no corroborative evidence linking the assessee to the alleged transaction. The material was treated as a dumb document because it did not speak to a concluded financial transaction, and no independent evidence established that the handwriting or notings belonged to the assessee&#039;s partner. The presumption under search and seizure provisions was inapplicable against the assessee for third-party material, and the denial of effective cross-examination, coupled with inadequate inquiry, vitiated the addition.</description>
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      <description>An addition for alleged undisclosed income could not be sustained where it rested solely on an image recovered from a third party&#039;s mobile phone, with no corroborative evidence linking the assessee to the alleged transaction. The material was treated as a dumb document because it did not speak to a concluded financial transaction, and no independent evidence established that the handwriting or notings belonged to the assessee&#039;s partner. The presumption under search and seizure provisions was inapplicable against the assessee for third-party material, and the denial of effective cross-examination, coupled with inadequate inquiry, vitiated the addition.</description>
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