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    <title>2025 (12) TMI 1270 - ITAT MUMBAI</title>
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    <description>Whether an addition u/s 69 could be sustained for alleged &quot;on-money&quot; cash payment towards purchase of shop premises based solely on third-party seized material and an employee&#039;s statement was the dominant issue. The Tribunal held that where the assessee denied any cash payment, the AO was required to confront the assessee with the incriminating material, produce corroborative evidence linking the assessee, and afford cross-examination of the deponent; reliance on uncorroborated third-party documents/statements without such safeguards violated settled evidentiary principles. As no seized document explicitly named the assessee and cross-examination was denied despite request, the addition was deleted and the appeal was allowed in favour of the assessee.</description>
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      <title>2025 (12) TMI 1270 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783730</link>
      <description>Whether an addition u/s 69 could be sustained for alleged &quot;on-money&quot; cash payment towards purchase of shop premises based solely on third-party seized material and an employee&#039;s statement was the dominant issue. The Tribunal held that where the assessee denied any cash payment, the AO was required to confront the assessee with the incriminating material, produce corroborative evidence linking the assessee, and afford cross-examination of the deponent; reliance on uncorroborated third-party documents/statements without such safeguards violated settled evidentiary principles. As no seized document explicitly named the assessee and cross-examination was denied despite request, the addition was deleted and the appeal was allowed in favour of the assessee.</description>
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