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    <title>2025 (3) TMI 1702 - ITAT NAGPUR</title>
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    <description>Addition for unexplained expenditure under section 69C could not be sustained on the basis of third-party seized receipts and impounded diary entries alone. The Revenue&#039;s papers were found from premises of other persons, were neither signed nor acknowledged by the assessee, and were not backed by corroborative evidence linking the assessee to any alleged on-money payment. As the registered sale deed and sale agreement reflected the same consideration, the presumption under sections 132(4A) and 292C was inapplicable because the documents were not found from the assessee&#039;s possession. The deletion of the addition was therefore upheld and the Revenue&#039;s challenge failed.</description>
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    <pubDate>Mon, 03 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 1702 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=469223</link>
      <description>Addition for unexplained expenditure under section 69C could not be sustained on the basis of third-party seized receipts and impounded diary entries alone. The Revenue&#039;s papers were found from premises of other persons, were neither signed nor acknowledged by the assessee, and were not backed by corroborative evidence linking the assessee to any alleged on-money payment. As the registered sale deed and sale agreement reflected the same consideration, the presumption under sections 132(4A) and 292C was inapplicable because the documents were not found from the assessee&#039;s possession. The deletion of the addition was therefore upheld and the Revenue&#039;s challenge failed.</description>
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      <pubDate>Mon, 03 Mar 2025 00:00:00 +0530</pubDate>
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