No Section 68 Addition Without Seized Material Link & corroborative evidence

Parag Motilal Savla Vs ITO (ITAT Mumbai)

The case centers around search and seizure operations conducted at M/s Evergreen Enterprises, during which certain documents were seized, and statements were recorded. The AO interpreted these documents as evidence of cash loans given by the assessee, Parag Motilal Savla, to Shri Nilesh Bharani. This interpretation was based on the accountant’s explanation of how to decode the entries in the seized documents.

Interpretation of Seized Documents:

• The AO based his conclusion on the decoded entries, alleging that these pertained to cash loans given by the assessee.

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