On-Money Addition Deleted – No Evidence Beyond Third-Party Pen Drive & Statements

Ramesh Kumar Puraji Jain Vs DCIT (ITAT Mumbai) Mumbai ITAT deleted additions made u/s 69 towards alleged on-money payment in cash for purchase of a shop in the Platinum Mall project (Rubberwala Group search cases). The Tribunal held that: The entire addition was based on a pen drive (Excel sheets) seized from a third party and statements of builder’s employees, without any direct evidence against the assessee No cash receipt, voucher, ledger, or incriminating document linking the assessee to cash payment was found The assessee had paid full consideration through banking channels, even highe...