Opportunity for Rebuttal Required When Using Third-Party Evidence Against Assessee u/s 132(4) of Income Tax Act.

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....Use of materials seized and the statement furnished by the third parties against the assessee - the opportunity for the rebuttal to the assessee for the seized documents and the statements recorded under section 132(4) of the Act are sine qua non in order to meet the principles of natural justice. This requirement has to be complied with by the revenue even in a situation where the assessee does not demand for the seized materials/statements recorded under section 132(4) of the Act if revenue seeks to make the addition on the basis of such material and statement. - AT....