Additions based on third-party documents deleted due to lack of direct evidence and no AO satisfaction under Section 147

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The ITAT held that additions based on documents recovered from third parties cannot be sustained against the assessee company absent direct linkage or corroborative evidence. Since no satisfaction was recorded by the AO under section 147 regarding the seized materials and no opportunity for cross-examination of third parties was granted, the additions on account of alleged unaccounted transactions and valuation discrepancies were deleted. The tribunal emphasized that documents found in possession of third parties pertain only to those persons and cannot bind the assessee without independent verification. Consequently, additions totaling over Rs. 3.46 crore confirmed by the CIT(A) were reversed. The reliance on digital data and valuation rep.........