#third-party evidence

ITAT Agra quashed a Rs.16.28 lakh addition under Section 69 after ruling that revenue cannot rely solely on unauthenticated Excel data from a third-party search without corroboration or opportunity for cross-examination. This reinforces that digital evidence, however voluminous, must meet basic standards of natural justice to justify tax additions - a critical safeguard for taxpayers facing algorithmic or bulk data-driven assessments.

CESTAT rules that Cenvat credit cannot be denied based solely on third-party statements or fake invoices unless the Revenue proves the assessee's knowledge of fraud or provides corroborative evidence. The ruling reinforces natural justice principles, requiring direct evidence linking the assessee to fraudulent transactions to disallow credit claims.

ITAT Mumbai rules that additions under Section 69 of the Income-tax Act for unexplained investments require substantive evidence beyond third-party statements or Excel data from search proceedings. The assessee must be afforded an opportunity for cross-examination to uphold natural justice principles, invalidating additions made without such corroboration.

ITAT Guwahati rules that failure to disclose third-party evidence gathered during search operations violates principles of natural justice under the Income Tax Act. The ruling reinforces the assessee's right to fair rebuttal, impacting tax assessment procedures nationwide.

ITAT Mumbai rules that additions under Section 153C of the Income Tax Act cannot be sustained solely on third-party statements or seized electronic data unless corroborated and the assessee is given an opportunity for cross-examination. The judgment reinforces principles of natural justice in tax assessments, impacting taxpayers facing similar proceedings.