https://www.taxtmi.com/caselaws?id=791396 Additions for alleged cash on-money on shop purchases could not be sustained where they were based only on a third party's Excel sheet and statement, without any independent corroboration linking the purchaser to the alleged payment. The material had no supporting receipt, diary, acknowledgement, or other contemporaneous evidence from the assessee, and its evidentiary value depended entirely on the maker's statement. Where adverse third-party material is relied on, fairness requires meaningful confrontation and an effective opportunity to rebut it, including cross-examination when the statement is material. In the absence of corroborative evidence, the additions were treated as resting on suspicion rather than proof and were deleted. en-us Fri, 27 Mar 2026 00:00:00 +0530 Tue, 12 May 2026 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791396 Additions for alleged cash on-money on shop purchases could not be sustained where they were based only on a third party's Excel sheet and statement, without any independent corroboration linking the purchaser to the alleged payment. The material had no supporting receipt, diary, acknowledgement, or other contemporaneous evidence from the assessee, and its evidentiary value depended entirely on the maker's statement. Where adverse third-party material is relied on, fairness requires meaningful confrontation and an effective opportunity to rebut it, including cross-examination when the statement is material. In the absence of corroborative evidence, the additions were treated as resting on suspicion rather than proof and were deleted. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791396