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    <title>2026 (4) TMI 1544 - ITAT DELHI</title>
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    <description>Additions under section 153C could not be sustained where the alleged incriminating chats, statements, summary sheets and other electronic material lacked reliable corroboration and did not establish a dependable evidentiary nexus with the assessee. The Tribunal treated the third-party statement and electronic material as insufficiently credible, noting that the relied-upon document was not shown to be a contemporaneous business record and surrounding circumstances did not support the alleged receipt of amounts. On that basis, the Revenue&#039;s challenge failed, the departmental appeals were dismissed, and the assessee&#039;s cross-objections were dismissed as academic, leaving the first appellate relief undisturbed.</description>
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      <description>Additions under section 153C could not be sustained where the alleged incriminating chats, statements, summary sheets and other electronic material lacked reliable corroboration and did not establish a dependable evidentiary nexus with the assessee. The Tribunal treated the third-party statement and electronic material as insufficiently credible, noting that the relied-upon document was not shown to be a contemporaneous business record and surrounding circumstances did not support the alleged receipt of amounts. On that basis, the Revenue&#039;s challenge failed, the departmental appeals were dismissed, and the assessee&#039;s cross-objections were dismissed as academic, leaving the first appellate relief undisturbed.</description>
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