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    <title>2026 (6) TMI 32 - ITAT MUMBAI</title>
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    <description>Additions under section 69/69A could not be sustained where they were based only on seized third-party Excel sheets and a related statement, without independent corroboration linking the assessee to the entries. A mere name reference and mobile number were insufficient when the sheets covered multiple persons, were not properly decoded or quantified, and no bank trail, cash movement, confirmations, or direct transaction evidence was produced. The assessee had also sought cross-examination of the persons whose statements were relied upon, but no effective opportunity was given. On these facts, the electronic records were treated as uncorroborated material and the additions were held unsustainable and directed to be deleted.</description>
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      <title>2026 (6) TMI 32 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=792651</link>
      <description>Additions under section 69/69A could not be sustained where they were based only on seized third-party Excel sheets and a related statement, without independent corroboration linking the assessee to the entries. A mere name reference and mobile number were insufficient when the sheets covered multiple persons, were not properly decoded or quantified, and no bank trail, cash movement, confirmations, or direct transaction evidence was produced. The assessee had also sought cross-examination of the persons whose statements were relied upon, but no effective opportunity was given. On these facts, the electronic records were treated as uncorroborated material and the additions were held unsustainable and directed to be deleted.</description>
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