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    <title>2023 (11) TMI 436 - ITAT SURAT</title>
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    <description>An addition for alleged suppression of OPD receipts from zero-receipt patients was deleted because it was based on an estimated average consultancy fee and suffered from the same infirmities as the deleted zero-receipt IPD addition in connected matters. The Tribunal applied the principle of consistency and accepted that the estimate rested on presumption, with the material not properly confronted to the assessee. The alternative objections on lack of show-cause and the admissibility of electronic record were left academic. The issue was decided in favour of the assessee.</description>
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      <description>An addition for alleged suppression of OPD receipts from zero-receipt patients was deleted because it was based on an estimated average consultancy fee and suffered from the same infirmities as the deleted zero-receipt IPD addition in connected matters. The Tribunal applied the principle of consistency and accepted that the estimate rested on presumption, with the material not properly confronted to the assessee. The alternative objections on lack of show-cause and the admissibility of electronic record were left academic. The issue was decided in favour of the assessee.</description>
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