No Section 69A Addition for Third-Party Pen Drive Data Without Confronting Taxpayer

Shital Dhorda Vs ITO (ITAT Mumbai) Conclusion: Addition made under Section 69A based only on statements and a pen drive that were never tested or corroborated was not justified as such evidence could not be treated as credible unless the taxpayer was confronted with it and given an opportunity to respond. Held: Assessee, had purchased a residential flat along with three family members from Natraj Realtors. The property was registered during the assessment year 2012–13. The case was reopened by AO under Section 148 based on information received from a search conducted on the Kamala Group. It ...