Search-Based On-Money Claims Need Proof, Not Presumptions

Manish Mali Vs DCIT (ITAT Mumbai) On-Money Additions u/s 69 Collapse Without Cross-Examination & Corroboration — ITAT Mumbai ITAT Mumbai (D Bench) in a batch of appeals led by Manish Mali vs DCIT (ITA Nos. 6571, 6569 & 6568/Mum/2025 for AYs 2017-18 to 2019-20; along with connected appeals of Darpan Hiralal Mehta & Dinesh Megharam Choudhary; order dated 24.12.2025) has allowed all appeals, deleting on-money additions u/s 69 made pursuant to search-based assessments u/s 153C arising from the Rubberwala Group search. The additions were founded on third-party Excel sheets seized from...