Held that the addition made by the AO solely on the basis of the notings on one loose sheet of paper found during the course of search at the premises of a third person, Sanjay Bansal, which was in the handwriting of his employee Sushil Kumar, is not sustainable, more so as the AO did not allow an opportunity to the assessee to cross-examine Sushil Kumar. (AY.2011-12)
Subhash Chander Gupta v. ITO (2025) 235 TTJ 883 (Chd)(Trib)
S. 69: Unexplained investments-Income from undisclosed sources-Search-Notings on loose paper-Third-party presumption-Failure to give an opportunity of cross-examination-Addition was deleted. [S.132, 132(4)]
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