https://www.taxtmi.com/caselaws?id=782648 ITAT Ahmedabad (AT) upheld the order of CIT(A) deleting additions u/s 69C and 69B made on the basis of an unsigned Excel sheet found on the laptop of a third-party employee of a developer group. The Tribunal held that the AO failed to establish that the digital sheet belonged to the assessee, that its entries related to the assessee, or that any on-money was actually paid. Emphasizing that uncorroborated third-party loose sheets or digital data lack evidentiary value absent independent corroboration and opportunity of cross-examination, ITAT accepted the factual finding that construction costs were borne by the developer and that sale consideration was duly bifurcated, thereby dismissing the Revenue's appeal. en-us Tue, 25 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782648 ITAT Ahmedabad (AT) upheld the order of CIT(A) deleting additions u/s 69C and 69B made on the basis of an unsigned Excel sheet found on the laptop of a third-party employee of a developer group. The Tribunal held that the AO failed to establish that the digital sheet belonged to the assessee, that its entries related to the assessee, or that any on-money was actually paid. Emphasizing that uncorroborated third-party loose sheets or digital data lack evidentiary value absent independent corroboration and opportunity of cross-examination, ITAT accepted the factual finding that construction costs were borne by the developer and that sale consideration was duly bifurcated, thereby dismissing the Revenue's appeal. Case-Laws Income Tax Tue, 25 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782648