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    <title>2025 (6) TMI 490 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad held that the AO was not justified in making separate additions for both unaccounted receipts and unaccounted expenses from seized materials, as expenses would have been incurred from receipts. Following Navjivan Oil Mills precedent, seized materials must be read in entirety without pick-and-choose approach. The tribunal reduced profit margin from 14% to 13% on real estate business and allowed telescoping of unaccounted payments against receipts. Additions made without incriminating material for completed assessments were deleted following Abhisar Buildwell SC judgment, which established that AO lacks jurisdiction under Section 153A without seized materials. Assessee&#039;s appeal was allowed.</description>
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    <pubDate>Fri, 30 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 490 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=772377</link>
      <description>The ITAT Ahmedabad held that the AO was not justified in making separate additions for both unaccounted receipts and unaccounted expenses from seized materials, as expenses would have been incurred from receipts. Following Navjivan Oil Mills precedent, seized materials must be read in entirety without pick-and-choose approach. The tribunal reduced profit margin from 14% to 13% on real estate business and allowed telescoping of unaccounted payments against receipts. Additions made without incriminating material for completed assessments were deleted following Abhisar Buildwell SC judgment, which established that AO lacks jurisdiction under Section 153A without seized materials. Assessee&#039;s appeal was allowed.</description>
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