Assessing Officer's Reliance on Witness Statement Deemed Unsustainable in On-Money Property Payment Case.

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....On-money payment for purchase of immovable property - Though the assessee failed to discharge its onus by producing both the parties before the AO for examination and to establish that on-money was not paid, reliance by the AO as well as the CIT(A) on the statement of Jayaram for making the addition is also not sustainable because he was only an attesting witness to the document. - AT....