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    <title>Unexplained cash credit addition under section 68 upheld based on seized receipt acknowledging Rs. 4.25 crores &quot;on money&quot;</title>
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    <description>ITAT upheld addition under section 68 for unexplained cash credit based on seized receipt dated 13.05.2008 acknowledging &quot;on money&quot; of Rs. 4.25 crores. Twin assessees challenged addition claiming receipt was undated and no amount received. Tribunal rejected contentions, applying section 292C statutory presumption regarding seized documents&#039; correctness. However, ITAT reduced total addition from Rs. 5.25 crores to Rs. 4.25 crores as per receipt amount, rejecting revenue&#039;s extrapolation. Addition apportioned equally between assessees at 50% each. CIT(A)&#039;s restriction to Rs. 1,09,89,285 was overturned. Tribunal distinguished Bharat Engineering precedent regarding first-year business additions, noting complex web of group entity transactions. Appeals partially allowed with addition confirmed at Rs. 4.25 crores total.</description>
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    <pubDate>Thu, 19 Jun 2025 08:29:35 +0530</pubDate>
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      <title>Unexplained cash credit addition under section 68 upheld based on seized receipt acknowledging Rs. 4.25 crores &quot;on money&quot;</title>
      <link>https://www.taxtmi.com/highlights?id=89566</link>
      <description>ITAT upheld addition under section 68 for unexplained cash credit based on seized receipt dated 13.05.2008 acknowledging &quot;on money&quot; of Rs. 4.25 crores. Twin assessees challenged addition claiming receipt was undated and no amount received. Tribunal rejected contentions, applying section 292C statutory presumption regarding seized documents&#039; correctness. However, ITAT reduced total addition from Rs. 5.25 crores to Rs. 4.25 crores as per receipt amount, rejecting revenue&#039;s extrapolation. Addition apportioned equally between assessees at 50% each. CIT(A)&#039;s restriction to Rs. 1,09,89,285 was overturned. Tribunal distinguished Bharat Engineering precedent regarding first-year business additions, noting complex web of group entity transactions. Appeals partially allowed with addition confirmed at Rs. 4.25 crores total.</description>
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      <pubDate>Thu, 19 Jun 2025 08:29:35 +0530</pubDate>
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