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    <title>2026 (4) TMI 240 - ITAT MUMBAI</title>
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    <description>Third-party search material and statements, without corroborative evidence against the assessee, were insufficient to support an addition for alleged on-money payment. Where the assessment under section 153C rested on material seized from another person, but no seized document or independent evidence showed the assessee had paid cash over and above the recorded consideration, the adverse material had to be properly confronted and the assessee given an opportunity to cross-examine the deponents. In the absence of such natural justice compliance, the addition under section 69 and the consequential assessment action were not sustainable, and relief followed for the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789171</link>
      <description>Third-party search material and statements, without corroborative evidence against the assessee, were insufficient to support an addition for alleged on-money payment. Where the assessment under section 153C rested on material seized from another person, but no seized document or independent evidence showed the assessee had paid cash over and above the recorded consideration, the adverse material had to be properly confronted and the assessee given an opportunity to cross-examine the deponents. In the absence of such natural justice compliance, the addition under section 69 and the consequential assessment action were not sustainable, and relief followed for the assessee.</description>
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