https://www.taxtmi.com/caselaws?id=468693 Section 153C jurisdiction could not be assumed where seized documents and digital data from a third party did not directly mention or belong to the assessee and lacked a clear nexus with the impugned transaction; the initiation of proceedings was therefore unsustainable. Additions under section 69B also failed because they rested on a later DVO estimate and uncorroborated third-party material, without any cash trail, direct document, or reliable evidence of on-money payment; the valuation difference by itself was insufficient to prove unexplained investment. The ITAT thus rejected the Revenue's case and sustained deletion of the additions. en-us Thu, 18 Sep 2025 00:00:00 +0530 Fri, 15 May 2026 14:28:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468693 Section 153C jurisdiction could not be assumed where seized documents and digital data from a third party did not directly mention or belong to the assessee and lacked a clear nexus with the impugned transaction; the initiation of proceedings was therefore unsustainable. Additions under section 69B also failed because they rested on a later DVO estimate and uncorroborated third-party material, without any cash trail, direct document, or reliable evidence of on-money payment; the valuation difference by itself was insufficient to prove unexplained investment. The ITAT thus rejected the Revenue's case and sustained deletion of the additions. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468693