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    <title>2019 (8) TMI 1275 - ALLAHABAD HIGH COURT</title>
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    <description>Additions based on alleged investment in potatoes and an alleged cash discrepancy were deleted because they rested on presumption rather than material evidence. The assessee operated a licensed cold storage business under the U.P. Regulation of Cold Storage Act, 1976, and the record showed no breach of the statutory licensing scheme or proof of purchase, sale, or unaccounted stock. For the cash issue, the Tribunal held that the facts did not attract sections 68 or 69A of the Income Tax Act, 1961, as the matter was at most a difference between book cash and cash physically found, not unexplained money in books. The High Court found no manifest illegality and upheld the deletion.</description>
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      <link>https://www.taxtmi.com/caselaws?id=385086</link>
      <description>Additions based on alleged investment in potatoes and an alleged cash discrepancy were deleted because they rested on presumption rather than material evidence. The assessee operated a licensed cold storage business under the U.P. Regulation of Cold Storage Act, 1976, and the record showed no breach of the statutory licensing scheme or proof of purchase, sale, or unaccounted stock. For the cash issue, the Tribunal held that the facts did not attract sections 68 or 69A of the Income Tax Act, 1961, as the matter was at most a difference between book cash and cash physically found, not unexplained money in books. The High Court found no manifest illegality and upheld the deletion.</description>
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