U/s 153C Additions on Alleged On-Money Deleted – No Corroboration & No Cross-Examination

Ashok Chunilal Mali Vs ACIT (ITAT Mumbai) The Mumbai ITAT deleted additions made under Section 69 in a 153C proceeding arising from the Rubberwala Group search, where the AO alleged on-money payments for shop purchases based on third-party evidence. The additions were primarily based on: Excel data found in a pen drive of a third-party employee, and Statements recorded from Rubberwala Group personnel claiming cash components in transactions. The Tribunal observed that: The assessee had denied any cash payment, and no incriminating material was found from the assessee. The entire case of the...