On-Money Additions Deleted as Based Solely on Third-Party Excel Data Without Proof & Opportunity to Cross-Examine Witness

Hariram Jagaji Chaudhari Vs DCIT (ITAT Mumbai) The present appeals concern multiple assessment years arising from a common order passed by the Commissioner (Appeals), involving additions made on account of alleged unaccounted cash payments (“on-money”) in relation to purchase of a shop in a commercial project. The background of the case lies in a search and seizure operation conducted under Section 132 in the case of a real estate developer group and its key personnel. During the search, digital material in the form of an Excel sheet was found from a key employee responsible for handling s...