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    <title>2025 (12) TMI 1832 - ITAT MUMBAI</title>
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    <description>Additions under section 69 based solely on third-party statements, pen-drive data and other search material cannot be sustained unless the adverse material is confronted to the assessee, the witnesses are offered for cross-examination, and the material is independently corroborated by credible evidence linking it to the assessee. Here, no independent documentary evidence showed cash payment by the assessee, the material was not furnished for rebuttal, and the persons relied on were not produced for cross-examination. The untested and uncorroborated evidence could not form the sole basis of the addition, so it was deleted.</description>
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      <description>Additions under section 69 based solely on third-party statements, pen-drive data and other search material cannot be sustained unless the adverse material is confronted to the assessee, the witnesses are offered for cross-examination, and the material is independently corroborated by credible evidence linking it to the assessee. Here, no independent documentary evidence showed cash payment by the assessee, the material was not furnished for rebuttal, and the persons relied on were not produced for cross-examination. The untested and uncorroborated evidence could not form the sole basis of the addition, so it was deleted.</description>
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