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    <title>2026 (6) TMI 1114 - ITAT BANGALORE</title>
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    <description>Protective additions in search assessment proceedings cannot stand where they rest only on loose sheets, scribblings and unsubstantiated jottings without signatures, reliable narration or corroborative evidence. The Tribunal held that the rebuttable presumptions under section 132(4A) and section 292C do not dispense with independent proof, and that denial of effective cross-examination further weakens the revenue case. As the corresponding substantive additions in the trust&#039;s case had already been deleted for want of evidentiary support, the protective additions in the assessee&#039;s hands were also deleted and the revenue appeals were dismissed.</description>
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    <pubDate>Thu, 21 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 1114 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=793733</link>
      <description>Protective additions in search assessment proceedings cannot stand where they rest only on loose sheets, scribblings and unsubstantiated jottings without signatures, reliable narration or corroborative evidence. The Tribunal held that the rebuttable presumptions under section 132(4A) and section 292C do not dispense with independent proof, and that denial of effective cross-examination further weakens the revenue case. As the corresponding substantive additions in the trust&#039;s case had already been deleted for want of evidentiary support, the protective additions in the assessee&#039;s hands were also deleted and the revenue appeals were dismissed.</description>
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      <pubDate>Thu, 21 May 2026 00:00:00 +0530</pubDate>
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