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    <title>2023 (8) TMI 812 - ITAT MUMBAI</title>
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    <description>The Tribunal upheld the decision of the Commissioner Of Income Tax (Appeals) to delete the substantial addition of Rs. 37,86,70,325/- due to a mismatch between income reported in form 26AS and recorded in the books of accounts. The Tribunal recognized the assessee&#039;s business model of acquiring and dealing in unguaranteed residuary interest in assets rented to customers, clarifying that the income earned was not rental income but from this business activity. The Assessing Officer&#039;s failure to understand the business model led to the dismissal of their appeal, with the consequential order filed by the assessee deemed infructuous.</description>
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      <link>https://www.taxtmi.com/caselaws?id=441833</link>
      <description>The Tribunal upheld the decision of the Commissioner Of Income Tax (Appeals) to delete the substantial addition of Rs. 37,86,70,325/- due to a mismatch between income reported in form 26AS and recorded in the books of accounts. The Tribunal recognized the assessee&#039;s business model of acquiring and dealing in unguaranteed residuary interest in assets rented to customers, clarifying that the income earned was not rental income but from this business activity. The Assessing Officer&#039;s failure to understand the business model led to the dismissal of their appeal, with the consequential order filed by the assessee deemed infructuous.</description>
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