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    <title>2022 (7) TMI 1253 - ITAT JABALPUR</title>
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    <description>Reassessment proceedings were upheld where the objection to sanction under section 151 was unsupported by reliable material and the assessee failed to rebut the presumption of regularity attached to official acts. On the bank-transaction additions, the assessee did not substantiate the claim of a cheque-issue or accommodation-entry business, yet the record did not justify taxing the entire credits as income. The taxable amount was restricted to the unexplained component and the profit element reasonably attributable to the activity, with telescoping applied on the available material. The additions were therefore modified rather than sustained in full.</description>
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      <link>https://www.taxtmi.com/caselaws?id=425698</link>
      <description>Reassessment proceedings were upheld where the objection to sanction under section 151 was unsupported by reliable material and the assessee failed to rebut the presumption of regularity attached to official acts. On the bank-transaction additions, the assessee did not substantiate the claim of a cheque-issue or accommodation-entry business, yet the record did not justify taxing the entire credits as income. The taxable amount was restricted to the unexplained component and the profit element reasonably attributable to the activity, with telescoping applied on the available material. The additions were therefore modified rather than sustained in full.</description>
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