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    <title>Appeal allowed: Rs.23.78 crore addition deleted; s.153A Excel/third-party documents deemed unsupported for lack of corroboration; s.12A/s.11 exemption retained</title>
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    <description>The ITAT allowed the assessee&#039;s appeal, holding that additions made under s.153A based on seized Excel/loose third-party documents were unsupported &quot;dumb&quot; evidence and lacked requisite corroboration (no cash seizure, asset trace or payer confirmation), inconsistent witness accounts, and no utilization trail for the alleged huge receipts; the Tribunal set aside the CIT(A)&#039;s finding and directed the AO to delete the Rs.23.78 crore addition. The ITAT further held the assessee retained registration under s.12A for the year in issue and, absent a sustainable finding under s.13(1)(c), is entitled to exemption under s.11. Additions predicated on materials extraneous to the relevant AY were also held unsustainable.</description>
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    <pubDate>Mon, 15 Sep 2025 08:26:13 +0530</pubDate>
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      <title>Appeal allowed: Rs.23.78 crore addition deleted; s.153A Excel/third-party documents deemed unsupported for lack of corroboration; s.12A/s.11 exemption retained</title>
      <link>https://www.taxtmi.com/highlights?id=92530</link>
      <description>The ITAT allowed the assessee&#039;s appeal, holding that additions made under s.153A based on seized Excel/loose third-party documents were unsupported &quot;dumb&quot; evidence and lacked requisite corroboration (no cash seizure, asset trace or payer confirmation), inconsistent witness accounts, and no utilization trail for the alleged huge receipts; the Tribunal set aside the CIT(A)&#039;s finding and directed the AO to delete the Rs.23.78 crore addition. The ITAT further held the assessee retained registration under s.12A for the year in issue and, absent a sustainable finding under s.13(1)(c), is entitled to exemption under s.11. Additions predicated on materials extraneous to the relevant AY were also held unsustainable.</description>
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      <pubDate>Mon, 15 Sep 2025 08:26:13 +0530</pubDate>
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