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    <title>2026 (6) TMI 1386 - ITAT MUMBAI</title>
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    <description>An addition under section 69 cannot be sustained where it rests solely on third-party statements and electronic material, with no independent corroboration, no incriminating material from the assessee, and no effective cross-examination. On those facts, the ITAT held the addition invalid and deleted it. The enhancement by the CIT(A) and the consequential direction to initiate proceedings under section 269SS also failed because they were based on the same uncorroborated material; once the primary addition was set aside, the consequential direction could not survive. The appeal was allowed and the alleged cash-payment addition was removed in full.</description>
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      <title>2026 (6) TMI 1386 - ITAT MUMBAI</title>
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      <description>An addition under section 69 cannot be sustained where it rests solely on third-party statements and electronic material, with no independent corroboration, no incriminating material from the assessee, and no effective cross-examination. On those facts, the ITAT held the addition invalid and deleted it. The enhancement by the CIT(A) and the consequential direction to initiate proceedings under section 269SS also failed because they were based on the same uncorroborated material; once the primary addition was set aside, the consequential direction could not survive. The appeal was allowed and the alleged cash-payment addition was removed in full.</description>
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      <pubDate>Tue, 23 Jun 2026 00:00:00 +0530</pubDate>
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