ITAT reversed the addition made by AO under section 69 for ...

Excel Sheet Found at Third Party's Premises Cannot Alone Justify Addition Under Section 69 for Unexplained Investments

March 15, 2025

Case Laws     Income Tax     AT

ITAT reversed the addition made by AO under section 69 for unexplained investment. The addition was based solely on an excel sheet found at a third party's premises, which allegedly showed cash loans advanced by the appellant. The Tribunal held that the excel sheet alone was insufficient evidence as it was neither authored by nor found in possession of the appellant. Without corroborative evidence establishing the appellant's connection to the alleged transactions, the addition was unsustainable. Following precedents in Appu Direct Pvt Ltd and Sant Lal, ITAT affirmed that liability cannot be fastened based solely on third-party materials without supporting evidence. The CIT(A)'s deletion of the addition was upheld.

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