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The entire disallowance in this case is based on third party information gathered by the Investigation Wing of the Department, which have not been independently subjected to further verification by the AO.

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Section 69 of the Income Tax Act, 1961 — Income from undisclosed sources — Disallowance set aside by Commissioner (A) was based solely on third party information which was not subjected to further scrutiny by AO and it was affirmed by Tribunal and High Court held that no substantial question of law arises as concurrent factual findings not shown to be perverse — Commissioner of income tax vs. Odeon Builders P. Ltd. [2019] 418 ITR 315 (SC)

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