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    <title>2025 (11) TMI 1932 - ITAT KOLKATA</title>
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    <description>Additions based solely on seized documents found with a third party were held unsustainable because the AO neither furnished the material to the assessee for rebuttal nor independently corroborated it or established any nexus between the assessee and the seized documents; unverified third-party material and suspicion cannot substitute evidence. Consequently, the addition was deleted. Estimation of income at 8% on alleged unaccounted purchases was also held impermissible since the AO did not reject the books of account under s.145(3) and failed to disprove the assessee&#039;s purchase bills and supplier confirmations; estimation is permissible only after valid rejection of books. Accordingly, the assessee&#039;s appeal was allowed and the addition confirmed by the CIT(A) was set aside.</description>
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    <pubDate>Fri, 14 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1932 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=465633</link>
      <description>Additions based solely on seized documents found with a third party were held unsustainable because the AO neither furnished the material to the assessee for rebuttal nor independently corroborated it or established any nexus between the assessee and the seized documents; unverified third-party material and suspicion cannot substitute evidence. Consequently, the addition was deleted. Estimation of income at 8% on alleged unaccounted purchases was also held impermissible since the AO did not reject the books of account under s.145(3) and failed to disprove the assessee&#039;s purchase bills and supplier confirmations; estimation is permissible only after valid rejection of books. Accordingly, the assessee&#039;s appeal was allowed and the addition confirmed by the CIT(A) was set aside.</description>
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      <pubDate>Fri, 14 Nov 2025 00:00:00 +0530</pubDate>
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