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Merely on suspicion based on information received from another authority, the assessing officer ought not to have made the additions without carrying out independent enquiry and without affording due opportunity to the respondent - assessee to controvert the statements made by the sellers before the other authority.

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Sec. 14A of Income Tax Act, 1961—Business Disallowance —Pr. CIT. vs. SHAPOORJI PALLONJI & CO. LTD.[2020] 23 ITCD Online 88 (BOM)