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    <title>2025 (4) TMI 1203 - ITAT MUMBAI</title>
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    <description>A special audit under section 142(2A) was upheld because the search and survey material showed complex, multi-city transactions and the timing did not, by itself, indicate prolongation of limitation. Additions under section 68 for cash deposits, credit entries and at-par cheque or demand draft transactions, along with the estimated commission, were deleted since the Revenue did not show that the amounts belonged to the assessee or satisfied the ingredients of unexplained cash credits. Disallowance of provision for standard assets was sustained as section 36(1)(viia) did not cover the assessee&#039;s co-operative credit society status, while prior period expenses and part of the section 40A(3) issue were remanded for fresh verification. Deduction under section 80P was allowed because the member-based transactions fell within the society&#039;s lawful business framework.</description>
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      <link>https://www.taxtmi.com/caselaws?id=769289</link>
      <description>A special audit under section 142(2A) was upheld because the search and survey material showed complex, multi-city transactions and the timing did not, by itself, indicate prolongation of limitation. Additions under section 68 for cash deposits, credit entries and at-par cheque or demand draft transactions, along with the estimated commission, were deleted since the Revenue did not show that the amounts belonged to the assessee or satisfied the ingredients of unexplained cash credits. Disallowance of provision for standard assets was sustained as section 36(1)(viia) did not cover the assessee&#039;s co-operative credit society status, while prior period expenses and part of the section 40A(3) issue were remanded for fresh verification. Deduction under section 80P was allowed because the member-based transactions fell within the society&#039;s lawful business framework.</description>
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