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    <title>2026 (4) TMI 91 - ITAT MUMBAI</title>
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    <description>Addition for unexplained investment based on alleged on-money payment could not be sustained where it rested only on third-party search material and statements, with no independent seized evidence specific to the assessee. The tribunal held that adverse material had to be properly confronted and that reliance on untested statements without allowing cross-examination breached natural justice. In the absence of corroborative evidence linking the assessee to cash over and above recorded consideration, the addition was deleted and the appeals were allowed.</description>
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      <description>Addition for unexplained investment based on alleged on-money payment could not be sustained where it rested only on third-party search material and statements, with no independent seized evidence specific to the assessee. The tribunal held that adverse material had to be properly confronted and that reliance on untested statements without allowing cross-examination breached natural justice. In the absence of corroborative evidence linking the assessee to cash over and above recorded consideration, the addition was deleted and the appeals were allowed.</description>
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