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    <title>2025 (10) TMI 1336 - ITAT MUMBAI</title>
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    <description>An addition for alleged on-money cannot be sustained where it is based only on third-party search material and statements, without confronting the adverse material to the assessee or allowing cross-examination of the persons relied upon. The record consisted of a pendrive, Excel data and search statements from the builder group, but the material was not found in the assessee&#039;s possession, was not furnished in full, and was unsupported by independent corroboration linking the assessee to unaccounted cash payment. The electronic material was also not shown to have been properly proved for admissibility. On this basis, the addition was deleted in favour of the assessee.</description>
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      <title>2025 (10) TMI 1336 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=465396</link>
      <description>An addition for alleged on-money cannot be sustained where it is based only on third-party search material and statements, without confronting the adverse material to the assessee or allowing cross-examination of the persons relied upon. The record consisted of a pendrive, Excel data and search statements from the builder group, but the material was not found in the assessee&#039;s possession, was not furnished in full, and was unsupported by independent corroboration linking the assessee to unaccounted cash payment. The electronic material was also not shown to have been properly proved for admissibility. On this basis, the addition was deleted in favour of the assessee.</description>
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