https://www.taxtmi.com/caselaws?id=779095 ITAT held that additions under s.10(3) of the BMA and related penalties were deleted: contemporaneous documents and the assessee's statement recorded during search established that the foreign companies' bank proceeds were withdrawn by a third party and not by the assessee, and the evidence found during search (including the third party's letter and audited balance sheets) attracted the presumptions under s.132(4A)/s.292C which went unrebutted. As the foreign entities were distinct from their shareholders and no beneficial receipt by the assessee was proved, the additions were disallowed and other legal contentions were left open. en-us Wed, 24 Sep 2025 00:00:00 +0530 Fri, 26 Sep 2025 17:13:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779095 ITAT held that additions under s.10(3) of the BMA and related penalties were deleted: contemporaneous documents and the assessee's statement recorded during search established that the foreign companies' bank proceeds were withdrawn by a third party and not by the assessee, and the evidence found during search (including the third party's letter and audited balance sheets) attracted the presumptions under s.132(4A)/s.292C which went unrebutted. As the foreign entities were distinct from their shareholders and no beneficial receipt by the assessee was proved, the additions were disallowed and other legal contentions were left open. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779095