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    <title>2025 (6) TMI 1301 - ITAT JAIPUR</title>
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    <description>The Tribunal allowed the appeal concerning unaccounted debtors of Rs. 96,19,000/- discovered during survey proceedings. The assessee had voluntarily offered this amount as business income in their ITR and paid tax at normal rates. The department sought to tax it under Section 115BBE at higher rates applicable to undisclosed income. The Tribunal held that without incriminating material to disprove the business nature of income, the department could not recharacterize it from business income to other sources. The voluntary disclosure and payment of tax at normal rates precluded application of Section 115BBE. The addition was set aside.</description>
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      <title>2025 (6) TMI 1301 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=773188</link>
      <description>The Tribunal allowed the appeal concerning unaccounted debtors of Rs. 96,19,000/- discovered during survey proceedings. The assessee had voluntarily offered this amount as business income in their ITR and paid tax at normal rates. The department sought to tax it under Section 115BBE at higher rates applicable to undisclosed income. The Tribunal held that without incriminating material to disprove the business nature of income, the department could not recharacterize it from business income to other sources. The voluntary disclosure and payment of tax at normal rates precluded application of Section 115BBE. The addition was set aside.</description>
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