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    <title>2025 (4) TMI 855 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad ruled in favor of the assessee regarding addition of undisclosed income under Section 69C read with Section 115BBE. The tribunal found that excess stocks discovered during survey were from purchases properly recorded in books with supporting bills, thus no unexplained investment existed. Section 69C was held inapplicable as there was no unexplained expenditure. The tribunal also ruled that amended Section 115BBE provisions (60% tax rate) were not applicable since the survey occurred on 29-09-2016, before the amendment&#039;s effective date. The PCIT&#039;s revision order was quashed.</description>
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      <title>2025 (4) TMI 855 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=768941</link>
      <description>The ITAT Ahmedabad ruled in favor of the assessee regarding addition of undisclosed income under Section 69C read with Section 115BBE. The tribunal found that excess stocks discovered during survey were from purchases properly recorded in books with supporting bills, thus no unexplained investment existed. Section 69C was held inapplicable as there was no unexplained expenditure. The tribunal also ruled that amended Section 115BBE provisions (60% tax rate) were not applicable since the survey occurred on 29-09-2016, before the amendment&#039;s effective date. The PCIT&#039;s revision order was quashed.</description>
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