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    <title>2022 (4) TMI 1382 - ITAT DELHI</title>
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    <description>An enhanced addition cannot be sustained without giving the assessee a reasonable opportunity to respond, because section 251(2) requires notice before any enhancement; the addition relating to cheque deposits was therefore deleted. Cash deposits linked to share transactions and a trading-like activity were not taxed in full under section 68, as the explanation was only partly acceptable; instead, only a reasonable profit element was brought to tax. The bank account being reflected in the balance sheet supported partial acceptance of the explanation, but the entire cash trail was not treated as satisfactorily proved.</description>
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      <description>An enhanced addition cannot be sustained without giving the assessee a reasonable opportunity to respond, because section 251(2) requires notice before any enhancement; the addition relating to cheque deposits was therefore deleted. Cash deposits linked to share transactions and a trading-like activity were not taxed in full under section 68, as the explanation was only partly acceptable; instead, only a reasonable profit element was brought to tax. The bank account being reflected in the balance sheet supported partial acceptance of the explanation, but the entire cash trail was not treated as satisfactorily proved.</description>
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