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        Case ID :

        2026 (1) TMI 1617 - AT - Income Tax

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        Section 69 addition for alleged cash on-money payments deleted where prior coordinate bench rulings covered identical facts and no new material was shown. Alleged cash on-money payments for purchase of a shop could not justify an addition under section 69 where the facts were identical to earlier coordinate ...
                      Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                        Provisions expressly mentioned in the judgment/order text.

                          Section 69 addition for alleged cash on-money payments deleted where prior coordinate bench rulings covered identical facts and no new material was shown.

                          Alleged cash on-money payments for purchase of a shop could not justify an addition under section 69 where the facts were identical to earlier coordinate bench rulings in the same project and the Revenue produced no new material, distinguishing fact, or contrary authority. Following those earlier decisions, the Tribunal held that the impugned addition was not sustainable on the record and deleted it in favour of the assessee.




                          Issues: Whether the addition made under section 69 of the Income-tax Act, 1961 on alleged cash on-money payments for purchase of a shop was sustainable.

                          Analysis: The appeals were found to involve identical facts to earlier coordinate bench decisions concerning alleged cash payments in the same project. The Revenue did not bring any new material, fact, or contrary decision to distinguish those rulings. The Tribunal therefore followed the earlier view and accepted the assessee's contention that the impugned addition could not be sustained on the record before it.

                          Conclusion: The addition under section 69 was deleted and the issue was decided in favour of the assessee.


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                          ActsIncome Tax
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