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    <title>S.69A additions deleted where undated loose paper from third party and audio lacked nexus to assessee</title>
    <link>https://www.taxtmi.com/highlights?id=93287</link>
    <description>ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party&#039;s residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO&#039;s reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.</description>
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    <pubDate>Mon, 13 Oct 2025 08:54:01 +0530</pubDate>
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      <title>S.69A additions deleted where undated loose paper from third party and audio lacked nexus to assessee</title>
      <link>https://www.taxtmi.com/highlights?id=93287</link>
      <description>ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party&#039;s residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO&#039;s reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.</description>
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      <pubDate>Mon, 13 Oct 2025 08:54:01 +0530</pubDate>
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