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    <title>2014 (10) TMI 324 - ITAT HYDERABAD</title>
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    <description>Section 68 additions for alleged unexplained loans were deleted where identity, banking-channel receipt, and surrounding material supported creditworthiness, and the assessee was not required to prove the source of the source. In development-agreement matters, capital gains were treated as arising only when construction was completed and the built-up area was handed over, where possession was permissive and title remained with the owners on execution. A finalised disallowance for consultancy charges under section 40(a)(ia) could not later be recharacterised as salary to avoid its tax effect. An addition under section 69 for alleged unexplained jewellery was deleted where wills found in search and surrounding family circumstances supported the explanation.</description>
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      <title>2014 (10) TMI 324 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=252190</link>
      <description>Section 68 additions for alleged unexplained loans were deleted where identity, banking-channel receipt, and surrounding material supported creditworthiness, and the assessee was not required to prove the source of the source. In development-agreement matters, capital gains were treated as arising only when construction was completed and the built-up area was handed over, where possession was permissive and title remained with the owners on execution. A finalised disallowance for consultancy charges under section 40(a)(ia) could not later be recharacterised as salary to avoid its tax effect. An addition under section 69 for alleged unexplained jewellery was deleted where wills found in search and surrounding family circumstances supported the explanation.</description>
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