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    <title>2022 (12) TMI 1472 - ITAT SURAT</title>
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    <description>The addition for alleged suppression of professional receipts from indoor patients was deleted because the material relied on was not confronted to the assessee, the assessment was based largely on presumptions, and the third-party information did not reliably support additions across multiple years. The record also showed that free treatment to some patients was part of the hospital practice, undermining the basis for inferring unrecorded receipts. Reducing the addition to a percentage of the alleged receipts did not cure the defective foundation, so the full addition was held unsustainable.</description>
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      <description>The addition for alleged suppression of professional receipts from indoor patients was deleted because the material relied on was not confronted to the assessee, the assessment was based largely on presumptions, and the third-party information did not reliably support additions across multiple years. The record also showed that free treatment to some patients was part of the hospital practice, undermining the basis for inferring unrecorded receipts. Reducing the addition to a percentage of the alleged receipts did not cure the defective foundation, so the full addition was held unsustainable.</description>
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