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ITAT affirmed the appellate findings and dismissed all grounds raised by the revenue. The Tribunal held that the addition for cash deposits during demonetisation could not be sustained because the revenue failed to controvert the finding that the assessee possessed sufficient cash on hand, and speculative inferences as to the source were impermissible. On characterization of sale proceeds, ITAT upheld CIT(A)'s factual conclusion that most land parcels constituted stock-in-trade while certain plots were consistently held as capital assets, rejecting the AO's contrary stance. With respect to interest deduction under section 24(b) on rental receipts, ITAT accepted CIT(A)'s allowance and reasoning that the return misdescribed the receipts, thereby dismissing the revenue's appeal.
ITAT affirmed the appellate findings and dismissed all grounds raised by the revenue. The Tribunal held that the addition for cash deposits during demonetisation could not be sustained because the revenue failed to controvert the finding that the assessee possessed sufficient cash on hand, and speculative inferences as to the source were impermissible. On characterization of sale proceeds, ITAT upheld CIT(A)'s factual conclusion that most land parcels constituted stock-in-trade while certain plots were consistently held as capital assets, rejecting the AO's contrary stance. With respect to interest deduction under section 24(b) on rental receipts, ITAT accepted CIT(A)'s allowance and reasoning that the return misdescribed the receipts, thereby dismissing the revenue's appeal.
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