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    <title>2016 (6) TMI 171 - ITAT MUMBAI</title>
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    <description>A disallowance cannot rest on suspicion where the assessee supports a cost of improvement claim with primary evidence such as an MOU, architect&#039;s certificate, invoices, cheque payments and TDS records, and the Revenue does not conduct adequate enquiry to rebut them; the addition on that issue was deleted, subject to limited verification of supporting documents. In relation to real estate project profits, the assessee&#039;s use of the percentage completion method and the claim that the same project income had already been offered across relevant years required year-wise verification; if full taxation of the project profit is confirmed, further addition would amount to double taxation. The matter was remitted for such verification.</description>
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      <title>2016 (6) TMI 171 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=328462</link>
      <description>A disallowance cannot rest on suspicion where the assessee supports a cost of improvement claim with primary evidence such as an MOU, architect&#039;s certificate, invoices, cheque payments and TDS records, and the Revenue does not conduct adequate enquiry to rebut them; the addition on that issue was deleted, subject to limited verification of supporting documents. In relation to real estate project profits, the assessee&#039;s use of the percentage completion method and the claim that the same project income had already been offered across relevant years required year-wise verification; if full taxation of the project profit is confirmed, further addition would amount to double taxation. The matter was remitted for such verification.</description>
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