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    <description>Protective addition arising from an unconsummated land transaction was held unsustainable because the agreement was cancelled, the property was later sold to third parties, and any undisclosed receipt, if taxable, belonged to the substantive assessment of the relevant party rather than a protective addition in the seller&#039;s hands. The unsecured loan addition was also deleted because the assessee produced lender confirmation, bank statement and evidence of agricultural land, while the record did not discredit the lender&#039;s identity, creditworthiness or the genuineness of the transaction. Additional evidence was admitted in the interest of substantial justice, and the revenue failed to rebut it.</description>
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