Section 153C Additions Deleted: No Corroboration for Third-Party Pen-Drive Evidence

Jayantilal Jesaram Purohit Vs DCIT (ITAT Mumbai)

153C Additions Based Only on Third-Party Pen-Drive and Statements Deleted for Want of Corroboration and Cross-Examination

In search-related assessments for AYs 2017-18 to 2019-20, additions under section 69 were made in the assessee’s hands based solely on an Excel file found in a pen drive seized from an employee of the Rubberwala group and statements of third-party persons alleging receipt of cash “on-money” for shop purchases. The assesse

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