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    <title>2026 (1) TMI 1618 - ITAT MUMBAI</title>
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    <description>Additions for alleged on-money in a shop purchase under section 153C cannot be sustained where they rest on a third-party statement and an Excel sheet found during search, but the assessee was not supplied the material, the assessment order did not set out the relevant entries or linkage, and no independent corroboration was produced. The Tribunal noted that untested digital data and third-party statements are insufficient on their own, especially where cross-examination is denied despite being sought. On that footing, the addition was deleted.</description>
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      <description>Additions for alleged on-money in a shop purchase under section 153C cannot be sustained where they rest on a third-party statement and an Excel sheet found during search, but the assessee was not supplied the material, the assessment order did not set out the relevant entries or linkage, and no independent corroboration was produced. The Tribunal noted that untested digital data and third-party statements are insufficient on their own, especially where cross-examination is denied despite being sought. On that footing, the addition was deleted.</description>
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