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    <title>2025 (7) TMI 43 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad upheld CIT(A)&#039;s decision restricting additions in search assessment under section 153C. For unaccounted receipts, tribunal confirmed 20% profit margin addition for A.Y. 2015-16 based on seized incriminating documents but deleted extrapolated additions for A.Ys. 2016-17 to 2018-19 lacking year-specific evidence. CIT(A) correctly applied principle that only embedded profit in unaccounted receipts is taxable. Regarding unaccounted land investment under section 69, tribunal upheld deletion as payments were made from already-taxed unaccounted receipts, avoiding double taxation. Addition under section 69C for alleged cash expenditure was also deleted as documents were seized from third party premises without establishing connection to assessee&#039;s business.</description>
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    <pubDate>Fri, 20 Jun 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=773975</link>
      <description>ITAT Ahmedabad upheld CIT(A)&#039;s decision restricting additions in search assessment under section 153C. For unaccounted receipts, tribunal confirmed 20% profit margin addition for A.Y. 2015-16 based on seized incriminating documents but deleted extrapolated additions for A.Ys. 2016-17 to 2018-19 lacking year-specific evidence. CIT(A) correctly applied principle that only embedded profit in unaccounted receipts is taxable. Regarding unaccounted land investment under section 69, tribunal upheld deletion as payments were made from already-taxed unaccounted receipts, avoiding double taxation. Addition under section 69C for alleged cash expenditure was also deleted as documents were seized from third party premises without establishing connection to assessee&#039;s business.</description>
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