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    <title>2026 (4) TMI 961 - ITAT MUMBAI</title>
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    <description>Addition for alleged cash on-money payment on purchase of shops could not be sustained where the Revenue relied only on a third-party statement and an Excel sheet recovered from a pen drive in another person&#039;s possession. The material was not confronted to the assessee, no opportunity of cross-examination was provided, and no independent corroborative evidence showed actual unexplained investment. The assessee&#039;s claim that the purchases were made through account payee cheques remained unrebutted, and the third-party digital data by itself did not conclusively prove unexplained expenditure or investment. The addition under section 69 was therefore deleted.</description>
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      <title>2026 (4) TMI 961 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=789892</link>
      <description>Addition for alleged cash on-money payment on purchase of shops could not be sustained where the Revenue relied only on a third-party statement and an Excel sheet recovered from a pen drive in another person&#039;s possession. The material was not confronted to the assessee, no opportunity of cross-examination was provided, and no independent corroborative evidence showed actual unexplained investment. The assessee&#039;s claim that the purchases were made through account payee cheques remained unrebutted, and the third-party digital data by itself did not conclusively prove unexplained expenditure or investment. The addition under section 69 was therefore deleted.</description>
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